Who we are
We are Cloudlabs Limited (C59731), Level 1, Office 1, 90, Psaila Street, Birkirkara, BKR 9073, Malta (‘Cloudlabs’) trading as ‘vouchercloud’ under license from Invitation Digital Limited, company number 06570126 and registered office at Springfield House, 45 Welsh Back, Bristol, BS1 4AG (‘Invitation Digital (UK)’).
Cloudlabs is the controller of your personal information, and is responsible for your personal information. All references in this policy to “vouchercloud”, “our”, “us” or “we” refer to Cloudlabs, or our group companies (including any company beneficially owned by the same shareholder/s) (‘group companies’), as appropriate. All references in this policy to “our website”, refer to the website owned by vouchercloud at www.vouchercloud.com.mt
We value your privacy and want to be accountable and fair to you as well as transparent with you in the way that we collect and use your personal information.
- What information we collect from you
- How your information is used
- How we store your information
- How you can access your information
The information we collect from you
We collect information from you in-order to show you the offers we think will be most relevant for you and give you the best possible service when using vouchercloud. We collect and process the following information;
Information you provide us
You may provide us with your personal information voluntarily. We may also receive information about you from third parties such as marketing agencies, market research companies, our suppliers, contractors, consultants, group companies, public websites and public agencies.
By registering for an account with our website or by downloading the vouchercloud application you will join the vouchercloud club and will start receiving news and updates regarding our latest vouchers. You will also be able to redeem our vouchers. Upon registration we ask you to provide us with personal information as follows;
Your name, email address, date of birth, postcode, city, country and gender.
We use this information to better personalise our service for you. We will never rent, sell or share your personal information with any other company for its own marketing purposes without your consent.
Information you provide on our partners’ websites
Information we get when you use our service
Your redemption information
When you use vouchercloud we will collect information about how you use our site and application. For example, when you redeem a voucher we’ll record details of the offer, the date and time and the device you’ve redeemed it on. We’ll use this information to personalise the offers we show you in future.
Your location information
When you use our application and website we may receive your location or ask to use it. We’ll use this to show you the offers which are near you. If you’re using our application, depending on your handset or the network you subscribe to, vouchercloud may automatically receive this information.
Your mobile phone information
When you use the vouchercloud application for the first time, we will receive a unique identifier for your phone if your handset manufacturer or network provide it. By downloading the vouchercloud app you are consenting that we may use this information to send you push notifications about our offers. We will not pass these details to third parties.
Your IDFA/Advertising Identifier
We also collect, where provided, your device’s IDFA/Advertising Identifier which is an anonymous ID provided by your operating system. We may pass this anonymised data to a third party partner for purposes of providing accurate and relevant advertising across various operating systems and devices and to analyse the effectiveness of advertising campaigns.
Details of how to opt out of IDFA/AAID data sharing can be found on your mobile device operating settings.
Cookies and similar technologies
For detailed information on the cookies we use and the purposes for which we use them, please refer to our cookies policy here.
How your information is used
To communicate with you
One of the main ways we use your information is to let you know about our offers and other promotions you might be interested in through email and push notifications.
Once you become a vouchercloud member we’ll send you email newsletters letting you know about our offers and deals. If you don’t wish to receive emails from us you can click the ‘unsubscribe’ link which will be found at the bottom of all emails from vouchercloud. You will be sent to an ‘update your preferences’ page in your account where you can opt out of different types of email or click unsubscribe from all.
These will be general notifications about our latest offers and location based messages when you are near a venue or shop with an offer. Both types of notification can be controlled in the settings section of the app.
Directly communicating with vouchercloud
When you send email or other communication to vouchercloud, we may retain the communication in order to serve you.
To personalise the content you receive
By collecting data on your activities on our website and application we’ll be able to better understand the types of offers that you’re interested. We’ll then present the most relevant offers for you on our website, application and through the communications we send you.
To provide a better experience
We also use your data for the improvement and maintenance of our website and to provide technical support for our website. We also use your data to evaluate your visit to the website and prepare reports or compile statistics to understand the type of people who use our website, how they use our website and to make our website more intuitive. Such details will be anonymised as far as reasonably possible and you will not be identifiable from the information collected.
To provide insight
Our use of technologies, including Segment.io and Google Analytics enables us to gather statistical information about how people use our site and application. As well as using this to improve what we do, we also share it with the brands we work with to give them feedback. The information we share will not identify you personally, it is statistical data and does not identify any personal details whatsoever.
You can download a tool that allows you to opt out of Google Analytics. The tool is available for download at https://tools.google.com/dlpage/gaoptout/.
We may also collect, use and store your personal information for the following additional reasons:
- to deal with any enquiries or issues you have about how we collect, store and use your personal information, or any requests made by you for a copy of the information we hold about you. If we do not have a contract with you, we may process your personal information for these purposes where it is in our legitimate interests for customer services purposes;
- for internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the security of company facilities, research and development, and to identify and implement business efficiencies, including group company reorganisation and re-branding. We may process your personal information for these purposes where it is in our legitimate interests to do so;
- to comply with any procedures, laws and regulations which apply to us – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so; and
- to establish, exercise or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so.
Legal Basis for Processing
- where neither (a) does not apply, use of your personal information is necessary for our legitimate interests or the legitimate interests of others (for example, to ensure the security of our website). Our legitimate interests are to:
- run, grow and develop our business;
- operate our website and the Vouchercloud app;
- carry out marketing, market research and business development;
- place, track and ensure fulfilment of orders with our suppliers; and
- for internal group administrative purposes
If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by contacting us at [email protected] and we will stop doing so. However, if you withdraw your consent, this may impact the ability for us to be able to provide offers and discounts and associated services to you (for example, we may not be able to provide marketing information to you regarding our suppliers’ products and services).
How and why we share your personal information with others
We may share your personal information with our group companies where it is in our legitimate interests to do so for internal administrative purposes (for example, for corporate strategy, compliance, auditing and monitoring, research and development and quality assurance). We will also share your information with Invitation Digital Limited (UK).
We will share your personal information with the following third parties or categories of third parties:
- we may share anonymised and aggregated statistical information with our suppliers and/or clients to demonstrate what interest there has been in any marketing campaigns we have assisted our suppliers and/or clients in carrying out;
- our other service providers and subcontractors, including payment processors, utility providers, suppliers of technical and support services, insurers, logistic providers, and cloud service providers;
- companies that assist in our marketing, advertising and promotional activities;
- analytics and search engine providers that assist us in the improvement and optimisation of our website; and
We will also disclose your personal information to third parties:
- where it is in our legitimate interests to do so to run, grow and develop our business:
- if we sell or buy any business or assets, we may disclose your personal information to the prospective seller or buyer of such business or assets;
- if substantially all of our or any of our affiliates’ assets are acquired by a third party, in which case personal information held by us will be one of the transferred assets;
- if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;
- in order to enforce or apply our terms and conditions for customers or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity; or
- to protect the rights, property, or safety of Vouchercloud, our staff, our customers or other persons. This may include exchanging personal information with other organisations for the purposes of fraud protection and credit risk reduction.
We may also disclose and use anonymised, aggregated reporting and statistics about users of our website/application or our goods and services for the purpose of internal reporting or reporting to our group or other third parties, and for our marketing and promotion purposes. None of these anonymised, aggregated reports or statistics will enable our users to be personally identified.
Save as expressly detailed above, we will never share, sell or rent any of your personal information to any third party without notifying you and, where necessary, obtaining your consent. If you have given your consent for us to use your personal information in a particular way, but later change your mind, you should contact us and we will stop doing so.
How we store your information
We keep your personal information for as long as you are registered for the vouchercloud service and no longer than necessary for the purposes for which the personal information is processed. The length of time for which we retain personal information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.
The main risk of our processing of your personal information is if it is lost, stolen or misused. This could lead to your personal information being in the hands of someone else who may use it fraudulently or make public, information that you would prefer to keep private.
For this reason, vouchercloud is committed to protecting your personal information from loss, theft and misuse. We take all reasonable precautions to safeguard the confidentiality of your personal information, including through use of appropriate organisational and technical measures.
In the course of provision of your personal information to us, your personal information may be transferred over the internet. Although we make every effort to protect the personal information which you provide to us, the transmission of information over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your personal information transmitted to our website/application and that any such transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to prevent unauthorised access to it.
Where we have given you (or where you have chosen) a password which enables you to access your online account, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
You have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact us via email at [email protected] at any time. You have the following rights:
Right of access.
You have a right of access to any personal information we hold about you. You can ask us for a copy of your personal information; confirmation as to whether your personal information is being used by us; details about how and why it is being used; and details of the safeguards which are in place if we transfer your information outside of the European Economic Area (“EEA”).
Right to update your information.
You have a right to request an update to any of your personal information which is out of date or incorrect.
Right delete your information.
You have a right to ask us to delete any personal information which we are holding about you in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the details below. We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort. You can ask us who the recipients are, using the contact details below.
Right to restrict use of your information.
You have a right to ask us to restrict the way that we process your personal information in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the details below.
We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort. You can ask us who the recipients are using the contact details below.
Right to stop marketing.
You have a right to ask us to stop using your personal information for direct marketing purposes. If you exercise this right, we will stop using your personal information for this purpose.
Right to data portability.
You have a right to ask us to provide your personal information to a third party provider of services.
This right only applies where we use your personal information on the basis of your consent or performance of a contract; and where our use of your information is carried out by automated means.
Right to object.
You have a right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our or another person’s legitimate interest.
We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period under applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.
If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.
Our website and services are not directed at children under the age of 18.
If you are a child under the age of 18 and we learn that we have inadvertently obtained personal information from you from our websites, or from any other source, then we will delete that information as soon as possible.
Please contact us at [email protected] if you are aware that we may have inadvertently collected personal information from a child under the age of 18.
We may collect and use your personal information for undertaking marketing by email and push notifications.
We may send you certain marketing communications (including electronic marketing communications) if it is in our legitimate interests to do so for marketing and business development purposes or, if you are a sole trader or a non-limited liability partnership if you have consented to receive such electronic marketing information.
However, we will always obtain your consent to direct marketing communications where we are required to do so by law and if we intend to disclose your personal information to any third party for such marketing.
If you wish to stop receiving marketing communications, you can contact us by email at [email protected]
Where we may transfer your personal information
Any personal data processed by Cloudlabs/IDL is stored on servers situated in the United Kingdom and Malta and in jurisdictions having equivalent protection. No personal data is shared with third parties based in countries which do not have equivalent data protection or confidentiality/secrecy laws in place.
Any personal data processed by Invitation Digital (UK) may be used, stored and/or accessed by staff operating outside the EEA working for us, other members of our group or suppliers. Further details on to whom your personal information may be disclosed are set out above.
- in the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield (see further https://www.privacyshield.gov/welcome); or
- in the case of entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them.
Further details on the steps we take to protect your personal information, in these cases is available from us on request by contacting us by email at [email protected] at any time.
Changes to this Policy
If you have any queries or complaints about our collection, use or storage of your personal information, or if you wish to exercise any of your rights in relation to your personal information, please contact [email protected] We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal information.
In accordance with Article 77 of the General Data Protection Regulation, you may also make a complaint to the Information and Data Protection Commissioner’s Office, or the data protection regulator in the country where you usually live or work. Alternatively, you may seek a remedy through the courts if you believe your rights have been breached.