Soreto

This is the Privacy & Cookies Policy (the ‘Policy’) of Soreto Limited, company number 10382580 of Second Floor, 12 Soho Square, London W1D 3QF (hereafter ‘Soreto’, ‘we’ or ‘us’). This Policy describes the ways in which Soreto collects and uses information about you when you use its website at HYPERLINK “https://soreto.com/” https://soreto.com/ (the “Website”) or choose to access any offer available via any Soreto generated lightbox either: (i) via a retail site on which you have just purchased goods or services; or (ii) via a Soreto generated link shared by a consumer who accessed a lightbox as detailed in (i) (each an “Offer”).

Soreto may change this Policy at any time in which case we shall notify you of any changes to this Policy by noting this on the Website and/or lightbox advertising the Offer (as applicable) The changes will apply to your use of the Website and/or Offer after we have given notice. If you do not wish to accept the new Policy you should not continue to use the Website and/or participate in any Offer (as applicable). If you continue to use the Website and/or participate in any Offer (as applicable) after the date on which the change comes into effect, your use of the Website and/or participation in any Offer (as applicable) indicates your agreement to be bound by the new Policy.

This Policy was last changed on September 2020.

• ICO registration: For the purposes of data protection legislation, Soreto is the controller for the processing of your personal data, with the exception of that information listed in 2(c) below, for which the applicable retailer is the data controller. Soreto has notified the Information Commissioner’s Office (“ICO”) of its processing of personal data. The notification indicates what data is processed by Soreto and for what purpose, and to which persons or entities the data will be provided. Soreto’s registration number is ZA221126.
• Information which is collected when you use the Website and/or participate in any Offer: Soreto may collect the following information from you when you use the Website and/or participate in any Offer (as applicable):
  1. any information which you choose to submit via the Website in order to contact Soreto about a particular request, namely your name, e-mail address and the message and subject of the message that you submit to Soreto;
  2. the information collected by Soreto’s use of cookies and similar technologies on the Website (please see Clause 9 below);
  3. your name and e-mail address if you choose to participate in any Offer via a retail site on which you have just purchased goods/services. Soreto obtains this information from the retailer that you have just purchased goods/services from or you have entered this data yourself;
• How the information collected about you listed in Clause 2 above is used by Soreto:The information about you described in Clause 2 may be used by Soreto as follows:
  1. the information in 2(a) is used by Soreto to process your particular contact request e.g., to answer any questions you have about Soreto’s products and/or services;
  2. the information in 2(b) is used to carry out various administrative tasks on the Website and to monitor and improve the functioning of the Website, as well as, in the case of the Tracking Cookies, to monitor your activity if you choose to participate in any Offer via a Soreto generated link shared by a consumer;
  3. the information in 2(c) is used to administer and provide the Offer to you;
  4. all of the information set out in Clause 2 is shared with third parties as described in Clause 5 below.
• Grounds for processing: Soreto relies on the following processing grounds:
  1. for the information in 2(a), contractual necessity as Soreto requires this information in order to be able to respond to the contact request submitted by you;
  2. for the information in 2(b), consent, as it is your choice as to whether to permit the use of cookies and similar technologies or not. Such consent is obtained from you: (a) in relation to the User Cookies and Tracking Cookies, if you choose to sign-up to the Offer/redeem an Offer as you will be informed that such cookies will be placed in doing so; and (b) in relation to the Third Party Cookies when you first visit the Website via the placing of our cookie consent notification;
  3. for the information in 2(c), Soreto is a data processor. You should consult the applicable retailer’s privacy policy for more details. Soreto is not responsible for the data handling practices of any retailer; and
  4. for the information in 2(d), consent as you choose to participate in the Offer by agreeing to accept it. Soreto is not, however, responsible for the actions of your friend in choosing to send the Offer to you and does not collect and/or process any data relating to you until you choose to participate in the Offer.
• Sharing information with third parties: Soreto shall not pass your information to any third party (other than as described in this clause). Your information may, subject to Soreto’s obligations to comply with applicable data protection legislation, be shared with the following third parties:
  1. its web hosting company;
  2. its server providers;
  3. having taken precautions to maintain the security of such information, Soreto may share this information with its regulator (the ICO);
  4. in anonymised form, Soreto may share the information with:
     1. any third party, in relation to the sale of some or all of Soreto’s business, or its assets, or as part of any business restructuring or reorganisation. Soreto will take steps with the aim of ensuring that your rights continue to be protected if your personal data is transferred in accordance with this clause;
     2. data aggregators and platform providers as part of an analysis of user metrics or sales performance;
     3. law enforcement agencies in compliance with law enforcement.
• Links to third party websites and third party adverts:Soreto is not responsible for the privacy policies and practices of other sites, including any retailer’s, even if you access them via the Website. You should check the policy of each site you visit and contact its owner or operator if you have any concerns or questions. In addition, if you link to the Website from a third party site or via a social network, Soreto is not responsible for the privacy policies and practices of the owners or operators of that third party site and recommends that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.
• Security: Soreto has implemented technology and policies to safeguard your privacy from unauthorised access and improper use.
• Storage and Data Retention: We store your personal data in the EEA and we retain your personal data for such time period as is necessary for us to do so, depending on the nature of the personal data in question.
• Cookies:
  1. What are Cookies? Cookies are small text files that are placed on your device when you use the Website. Soreto’s use of cookies is detailed below. Session cookies enable you to move from page to page within the Website and any information you enter will be remembered but is deleted when you close that page on the Website or after a short time. Persistent cookies allow us to remember your preferences and settings when you use the Website in the future.
  2. Disabling Cookies: The use of the cookies described above improves the functionality of the Website and your experience of using them. If you do not want these cookies to be served on your device, you are able to disable them by changing the settings within the Website. Please note that if you do decide to disable cookies you may not be able to access some of the Website, and some of the features of the Website may not function properly.
  3. Third Party Cookies: Third Party advertisers may place or read cookies on your browser or device in the Website (as indicated below). This Policy is applicable only to the use of cookies by Soreto and does not cover the use of cookies by any third parties (including advertisers or social media companies).
  4. More information: To find out more about how cookies work, how to manage and delete them and to see which ones have been set please visit www.aboutcookies.org or www.allaboutcookies.org.

Cookie Type	Purpose
User Cookies	Soreto uses reverbToken cookies which contain user details for users that have signed up to the Website. It tracks a user’s first name, last name and user type.
Tracking Cookies	Soreto uses the following tracking cookie, reflecting the client that the user has interacted with in order to stop clients from writing over other clients’ tracking data. This is stored when a user clicks on a Soreto link: soreto_chocolat_chip It contains information about the Soreto link clicked and when it happened. In addition to adding tracking cookies to the user’s browser Soreto also stores the Referrer, IP and, User-Agent of each click to identify trends and prevent fraud.
Third Party Cookies	Soreto uses the following third-party cookies, please click on any of them for further information: Google Analytics Solutions Hot Jar

• Exercising your rights: You can contact us using the details set out in Clause 11 below if you wish to: (i) access a copy of the personal data that we hold about you; (ii) correct any items of personal data that we hold about you; and/or (iii) have any items of personal data that we hold about you erased or object to our processing of such items of personal data. Please note that if this request relates to information that we obtain from a retailer we may ask you to contact the retailer directly to make the same request.
• Soreto Details: If at any time you would like to contact Soreto about your views on this Policy or any enquiry relating to your personal information, you can do so by sending an e-mail to us at  [email protected] or write to us at “Data Protection Query, Soreto Limited, Second Floor, 12 Soho Square, London W1D 3QF”. You also have the right to make a complaint to the ICO by contacting https://ico.org.uk/global/contact-us/ them at any time.