Published on 3rd April 2021.
Last updated on 3rd April 2021.
This Policy also helps us in complying with our applicable global data privacy laws, including without limitation the EU General Data Protection Regulation (“EU GDPR”) if you are located in the EEA, and the UK General Data Protection Regulation (the “UK GDPR”) if you are located in the UK, as applicable (each and collectively the “GDPR”, as applicable).
Who we are
This website is operated by Tuck Technology Limited, a company incorporated in England with the following registered number 12857517 and registered office at Kemp House, 152-160 City Road London, London, London, England, EC1V 2NX, and trading as tuck. For more information on tuck., see https://www.tuckapp.co/abouttuck.
We collect, use and are responsible for certain personal information about you. When we do so we are regulated under the GDPR which applies across the European Union and the United Kingdom and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
Throughout our Platform we may link to other websites and/or mobile applications owned and operated by certain trusted third parties to make additional products and services available to you. These other third party websites and/or mobile applications may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third party websites and/or mobile applications, please consult their privacy policies as appropriate.
Our collection and use of your personal information
We collect personal information about you directly when you connect to the Platform with your device (“Connect”, or “Connection”, as applicable); when you register on the Platform to create an account (“Register”); when we conduct regulatory checks on you in order to comply with our legal obligations, including without limitation to protect against anti-money laundering, fraud, credit risk and any other financial services related regulatory compliance (each and collectively “Regulatory Checks”); when you contact our customer services department with a request (“Customer Services Contact”) when you contact us and you are located in the EEA to make a request relating to your personal information pursuant to a right of yours under the GDPR or a similar regulation under another jurisdiction (“GDPR Contact”); when you withdraw rewards you have earned via the Platform (each and collectively “Rewards Withdrawal”); when you take part in a competition or survey on the Platform (each and collectively “Competition registration”, as applicable); and when you leave a comment anywhere on the Platform, including without limitation any blog post (each and collectively “Comments”, as applicable);.
Indirectly, we collect personal information from you when you use the Platform and a cookie is placed on your device by a third-party partner, such as Google Analytics (“Google Analytics Processing”).
The following details are the only personal information we collect about you:
your email address, name details when you Register (each and collectively “Registration Details”, as applicable);
your name, and any other information we obtain on you in support of Regulatory Checks (each and collectively “Regulatory Information”, as applicable);
your email address and name, and any other information you provide in a GDPR Contact (each and collectively “GDPR Compliance Details”, as applicable);
your email address and name, and any other information you provide in a Customer Services Contact (“Customer Services Details”);
your transaction details with tuck. Partner merchants via Plaid Data Processing to support the making of updates to you about Cashback earned (each and collectively “Cashback Details”, as applicable);
your name and bank details to support the making of any Rewards Withdrawal “Rewards Withdrawal Information”);
statistics in your usage behaviour when you are using the Platform (each and collectively “Usage Stats”, as applicable);
your IP address, country of location, geo-location and TOR/VPN status when you Connect to the Platform (each and collectively “Connection-derived Information”);
your email address, name during any Competition Registration (each and collectively “Competition Information”);
your name when you leave any Comments (“Interactive Information”); and
your unique ID in Google Analytics Processing (“Google Analytics Info”).
We use this personal information to:
Registration Details + Cashback Details + Rewards Withdrawal Information + Customer Services Details + Comments: to open your account and enable the supply of the services available on the Platform including without limitation customer administration, customer services (each and collectively as “Service Provision”, as applicable);
Regulatory Information + Connection-derived Information: to comply with the anti-money laundering, anti-terrorist financing, and any other regulations and laws that apply to the operation of the Platform (“Regulatory Compliance”);
GDPR Compliance Details: to enable you to make requests or queries to us in accordance with your rights under the GDPR (“GDPR Request Compliance”);
Usage Stats + Connection-derived Information: for our marketing and promotional activities (“Marketing”);
Usage Stats + Google Analytics Info + Connection-derived Information: to further develop and improve the Platform and Services (“Product Improvement”); and
Connection-derived Information: to enable and improve from time to time the safety and security of the Platform in compliance with our requirements under the GDPR (“GDPR Security Compliance”); and
Registration Details + Competition Information: to enable and administer our competitions and surveys (“Competitions and Surveys”).
This Platform is not intended for use by children and we do not knowingly collect or use personal information relating to children.
Our legal basis for processing your personal information
When we use your personal information we are required to have a legal basis for doing so. There are various different legal bases on which we may rely, depending on what personal information we process and why.
The legal bases we may rely on include:
“Consent” where you have given us clear consent for us to process your personal information for a specific purpose, as is the case with Marketing; Product Improvement; and Competitions and Surveys.
“Contract” where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract, as is the case for Service Provision; and
“Legal Obligation” where our use of your personal information is necessary for us to comply with the law (not including contractual obligations), such as with GDPR Security Compliance, GDPR Request Compliance and Regulatory Compliance.
So, to summarize:
When you Register, we collect your Registration Details to enable our Service Provision on the legal basis of Contract;
With each Customer Services Contact, we collect your Customer Services Details to enable our Service Provision on the legal basis of Contract;
With every Competition Registration, we will collect your Competition Information for Competitions and Surveys on the legal basis of Consent;
During Plaid’s Data Processing, we collect your transaction details with tuck. Partner merchants to enable our Service Provision to you on the basis of Contract;
With every Rewards we process your Withdrawal Information to enable our Service Provision to you on the basis of Contract;
During Regulatory Checks, we collect your Regulatory Information to enable our Regulatory Compliance on the basis of our Legal Obligation;
With each GDPR Contact, we collect your GDPR Compliance Details to enable our GDPR Compliance on the basis of our Legal Obligation;
When you use the Platform, we collect your Usage Stats and Google Analytics Info to enable our Marketing; and Product Improvement, on the legal basis of your Consent;
With every Connection, we collect your Connection-derived Information to enable our Marketing and Product Improvement, on the legal basis of your Consent; and to enable our Regulatory Compliance and GDPR Security Compliance on the basis of our Legal Obligation.
Who we share your personal information with
We routinely share certain personal information with third parties for certain purposes as detailed below:
To any merchant business that offers any rewards via our Platform (each and collectively the “Merchants”, as applicable);
All personal information we collect under this Policy to: HubSpot, Inc., 25 First Street, 2nd Floor, Cambridge, MA 02141 USA, Attn (“Hubspot”);
and Wix.com Inc., 500 Terry Francois Blvd., 6th Floor, San Francisco, CA 94158 USA. (“Wix”),
to securely store all your personal information; and Usage Stats to Hubspot and Wix to analyse how our customers use the services available in the Platform;
Transactions Details to: Plaid Financial Ltd, Attn: Legal, New Penderel House, 4th Floor
283-288 High Holborn, London, United Kingdom, WC1V 7HP (“Plaid”) so that you can link your bank account to access and earn cashback rewards as part of our Service Provision;
Google Analytics Info to: (“Google Analytics”) to track cookies and to analyse how frequently persons visit our Platform, with a view of improving and optimising our Platform;
All personal information we collect under this Policy to:
Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, L-1855, Luxembourg, ATTN: AWS EMEA Legal, (“AWS”), because we use AWS for the hosting of the Platform;
All personal information we collect under this Policy to Wix, because we also use Wix for the hosting of the Platform;
Cashback Details + Rewards Withdrawal Information to:
Stripe Inc, Stripe, 510 Townsend Street, San Francisco, CA 94103, USA
Attention: Stripe Legal (“Stripe:”) to collect payments from our merchants partners available on the Platform, and enable Rewards Withdrawals for Users;
Your Regulatory Information to credit reference agencies (“CRAs”), to assess creditworthiness and product suitability and other Regulatory Checks. The identities of the CRAs and the ways in which they may use and share personal information are explained in more detail at http://www.experian.co.uk/crain/index.html.
Some of those third party recipients may be based outside the United Kingdom and European Economic Area — for further information including on how we safeguard your personal data when this occurs, see ‘Transfer of your information out of the UK and EEA’ below.
We will share personal information with law enforcement or other authorities if required by applicable law.
We will not share your personal information with any other third party.
Whether information has to be provided by you, and if so why
We require you to provide the following personal information:
Registration Details to enable Service Provision;
Regulatory Information for Regulatory Compliance;
GDPR Compliance Details for GDPR Compliance;
Cashback Details for Service Provision; and
Some Connection-derived Information and Google Analytics Info for Regulatory Compliance; and
other Google Analytics Info for Service Provision.
We will inform you at the point of collecting information from you, whether you are required to provide the information to us.
The impact of our use of your personal information
The impact of our use of your personal information is that such use will enable the purposes referenced herein, and it will require us to secure your personal information to limit data breach risks that are inherent in our use of your personal information.
Transfer of your information out of the UK and EEA
We will not transfer your personal data outside of the area comprising the UK and EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.
Cookies and other tracking technologies
We would like to send you information about products and services, competitions and special offers, which may be of interest to you.
Where we have your consent, we may do this by post, email, telephone, text message (SMS) or automated call.
We will only ask whether you would like us and other businesses to send you marketing messages when you tick the relevant boxes when during Registration.
If you have previously agreed to being contacted in this way, you can unsubscribe at any time by emailing firstname.lastname@example.org. It may take up to 14 days for this to take place.
For more information on your rights in relation to marketing, see ‘Your rights’ below.
Under the GDPR you have a number of important rights free of charge. In summary, those include rights to:
fair processing of information and transparency over how we use your use personal information;
access to your personal information and to certain other supplementary information that this Policy is already designed to address;
require us to correct any mistakes in your information which we hold;
require the erasure of personal information concerning you in certain situations;
receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations;
object at any time to processing of personal information concerning you for direct marketing;
object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you;
object in certain other situations to our continued processing of your personal information;
otherwise restrict our processing of your personal information in certain circumstances; and
claim compensation for damages caused by our breach of any data protection laws.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
email us at email@example.com, or write to us at Kemp House, 152-160 City Road London, London, London, England, EC1V 2NX;
let us have enough information to identify you (eg account number, user name, registration details);
let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
let us know the information to which your request relates including any account or reference numbers, if you have them.
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to complain
We hope that we can resolve any query or concern you raise about our use of your information.
The GDPR also gives you the right to lodge a complaint with a supervisory authority, in particular in a European Economic Area state or in the United Kingdom if you work, normally live or if any alleged infringement of data protection laws occurred in the relevant state. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
How to contact us
Please contact us firstname.lastname@example.org, if you have any questions about this privacy notice or the information we hold about you.