Privacy & Cookies Policy
This Privacy & Cookies Policy (“Policy”) applies between you (the User of this App) and us (Shoalter Automation (UK) Limited, the owner and provider of this App). We take the privacy of your personal information very seriously. This Policy applies to our use of any and all your Data in relation to your use of this App.
This Policy should be read alongside, and in addition to, the Terms and Conditions, which can be found at: www.in-five.co.uk/terms-and-conditions.
Definitions
In this Policy, the following definitions are used:
| App | the application that you are currently using owned and provided by Shoalter Automation (UK) Limited. |
| Cookie | a small text file placed on your mobile device by this App when you visit certain parts and/or when you use certain features of this App. Details of the cookies used by this App are set out in section B, “Cookies Policy”. |
| Data | collectively all information that you submit to us via this App or which we collect through your use of this App. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws. |
| Data Protection Laws | any applicable law relating to the processing of Personal Data, including but not limited to: (i) the UK GDPR and the UK Data Protection Act, and (ii) the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011 & the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2018, and any national implementing and supplementary laws, regulations and secondary legislation. |
| Personal Data | any information about an individual from which that individual may be identified. It does not include data where the identity has been removed (anonymous data). |
| Shoalter Automation (UK) Limited, we or us | Shoalter Automation (UK) Limited, a company incorporated in England and Wales with registered number 13637578 whose registered office is at 320 Broadway, Salford, England, M50 2UE; |
| UK GDPR | the UK General Data Protection Regulation. |
| User or you | any person that accesses this App and is not either (i) employed by Shoalter Automation (UK) Limited and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Shoalter Automation (UK) Limited and accessing this App in connection with the provision of such services. |
Interpretation
In this Policy, unless the context requires a different interpretation:
– the singular includes the plural and vice versa;
– references to sections, sub-clauses, clauses, schedules or appendices are to sections, sub-clauses, clauses, schedules or appendices of this Privacy Policy;
– a reference to a person includes firms, companies, government entities, trusts and partnerships;
– “including” means “including without limitation”;
– reference to any statutory provision includes any modification or amendment of it; and
– the headings and sub-headings do not form part of this Privacy Policy.
A. Privacy Policy
Please read this Privacy Policy carefully.
Topics:
1. Scope of this Privacy Policy
2. What Data do we collect?
3. How do we collect your Data?
4. How will we use your Data?
5. Who will we share your Data with?
6. What happens if you do not provide your Data?
7. How long do we store your Data?
8. Keeping Data secure
9. Marketing
What are your data protection rights?
1. Scope of this Privacy Policy
This Privacy Policy applies only to the actions of yours and us with respect to this App. It does not extend to any applications that can be accessed from this App including any links we may provide to social media websites. For purposes of the applicable Data Protection Laws, we are the “data controller”. This means that we determine the purposes for which, and the manner in which, your Data is processed.
2. What Data do we collect?
We may collect Data, which includes Personal Data, from you:
– contact Information such as email addresses
– name (only when dealing with customer service cases, not when making payment)
– other user identifiers, such as Pixel ID, Facebook user ID, if you are logged in
– transaction data, including details of products and services you have purchased from us, the amounts you have agreed to pay and the dates of your order and delivery
– technical data, such as internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, device type, operating system and platform, Device ID, referrer, person using the website, the date, times and frequency with which you access this App and the way you use and interact with its content
– http headers: a standard web protocol sent between any browser request and any server on the internet, referrer, person using the website
– geographic location
– user token
– user preferences and behaviour, such as the pages you visit, button click data
– optional values, such as conversion value, page type,
in each case, in accordance with this Privacy Policy.
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.
3. How do we collect your Data?
We collect Data in the following ways:
3.1 Data provided to us by you:
– when you contact us through this App, by post or by e-mail;
– when you elect to receive marketing communications from us;
– when you use our services;
– when you contact our customer service support;
– when you enter a competition, promotion or survey;
– when you decide to send an invoice to yourself;
3.2 Data collected automatically:
– we automatically collect some information about your visit to this App. This information helps us to make improvements to this App content and navigation, and may include your IP address, the date, times and frequency with which you access this App and the way you use and interact with its content.
– we will collect your Data automatically via cookies, in line with the cookie settings on your device. For more information about cookies, and how we use them on this App, see section B, “Cookies Policy”.
4. How will we use your data?
We may use your Data from time to time when:
– it is necessary for the purposes of performing a contract with you, including:
– providing and managing your account;
– providing and managing your access to this App;
– supplying our products and services to you;
– providing you with customer support; or
– communicating with you.
– it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests, as examples:
– personalising and tailoring your experience on this App and our products, services and advertisements for you;
– assessing your creditworthiness;
– screening your orders for compliance with our terms and conditions and to detect fraud;
collecting and recovering money you owe to us;
– internal record-keeping in relation to matters such as your consent and preferences,
– analysing your use of our site and developing improvements to our products / services and this App; or
– preventing abuse of onboarding discounts.
the law requires so;
5. Who will we share your Data with?
We may share your Data with selected recipients including:
– Group companies. We may share Data with our group companies, some of which are located outside the UK.
– Service providers. We may engage service providers, some of which may be located outside the UK, to support or improve this App, including checkout.com (payment gateway), Gnatta (customer service support), GooglePay, ApplePay, Google Analytics, Yoti (for age verification for age-restricted products) and Meta Pixel. We will only transfer Data outside the UK where it is compliant with Data Protection Laws and the means of transfer provides adequate safeguards in relation to your Data. 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.
– Regulatory authorities, enforcement agencies, credit reference agencies or other third parties. We may share your Data with regulatory authorities or law enforcement agencies that request or demand it to comply with laws or regulations, or for the purpose of legal proceedings. If you give us Data that is wrong or we find out (or suspect) you are responsible for fraud, we may share your information with third parties such as law enforcement agencies, credit reference agencies and other affected third parties;
– Partners, if compelled to do so. If one of our partners who are processing information for us are compelled to do so by law, we may also be obliged to provide your Data to them;
– Emergency. If there is an emergency and we think you or other people are at risk.
If you are not satisfied with our processing of your Data, you have the right to object in certain circumstances (s ee the section A, clause 11, “What are your data protection rights” below).
6. What happens if you do not provide your Data?
We may not be able to provide you with the App if you do not provide your Data, but we will notify you if this is the case at the time.
7. How long do we store your Data?
We will only hold your Data on our systems for the period reasonably necessary to fulfill the purposes outlined in this Privacy Policy or until you request that the Data be deleted, unless:
– a longer retention period is required by law;
– your Data persists on backup or archival media for legal, tax or regulatory purposes even after we delete your Data; or
– we receive a complaint or reasonably believe there is a prospect of litigation in respect of our relationship with you.
To determine the appropriate retention period for Data, we consider the amount, nature and sensitivity of the Data, the potential risk of harm from unauthorised use or disclosure of your Data, the purposes for which we process your Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
8. Keeping Data secure
We will use technical and organisational measures to safeguard your Data, for example:
– a password and a user name that is unique to you to control the access of your account;
– secured servers to store your Data; and
– measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: privacy@in-five.co.uk.
If you want detailed information from Get Safe Online on how to protect your information and devices against fraud, identity theft, viruses and any other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
9. Marketing
We may use your Data to form a view on the products and services that might be of interest to you. This is how we decide which products, services and offers may be relevant for marketing to you.
You will receive marketing communications from us, if you have requested information from us or purchased products or services from us and you have not opted out of receiving such marketing communications.
We will obtain your express opt-in consent before we share your Data with other members of our corporate group and our partner companies for marketing purposes. You have the right at any time to stop us from contacting you for marketing purposes or giving your Data to other members of our corporate group and partner companies.
We may contact you by email, telephone, text message or post for these purposes.
If you no longer wish to be contacted for marketing purposes, please contact us via this e-mail address: privacy@in-five.co.uk.
10. What are your data protection rights?
We would like to make sure you are fully aware of all of your data protection rights which you are entitled below. Every user is entitled to the following:
The right to access – the right to request (i) copies of the Data we hold about you at any time, or (ii) that we modify, update or delete such Data. If we provide you with access to the Data we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
The right to rectification – You have the right to request us to correct any Data we hold which you believe is inaccurate or incomplete.
The right to erasure – You have the right to request us to erase your Data, under certain conditions.
The right to restrict processing – You have the right to request us to restrict the processing of your Data, under certain conditions.
The right to object to processing – You have the right to object to the processing of your Data, under certain conditions.
The right to data portability – You have the right to request that we transfer the Data that we hold to another organization, or directly to you, under certain conditions.
If you make a request, we will respond to you within 1 month.
B. Cookies policy
Please read this Cookies Policy carefully.
Topics:
1. What are cookies?
2. How do we use cookies?
3. What types of cookies do we use?
4. The cookies we set
5. How to manage your cookies
1. What are cookies?
A cookie is a small text file that is downloaded onto ‘terminal equipment’ (for example your computer or smartphone) when you access a website. It allows the website to recognise your device and store some information about your preferences or past actions on the website.
2. How do we use cookies?
This App may place and access certain cookies on your device. We use cookies to improve your experience of using this App and to improve the relevance of our range of products available to you. We have carefully chosen these cookies and taken steps to ensure that your privacy is protected and respected at all times.
All cookies used by this App are used in accordance with current Data Protection Laws.
3. What types of cookies do we use?
This App may place the following cookies:
Type of Cookie
| Type of Cookie | Purpose |
| Strictly Necessary cookies | These are cookies that are required for the operation of our App. They include, for example, cookies that enable you to log into secure areas of our App, use a shopping cart or make use of e-billing services. |
| Analytical/Performance cookies | They allow us to recognise and count the number of visitors and to see how visitors move around our App when they are using it. This helps us to improve the way our App works, for example, by ensuring that users are finding what they are looking for easily. |
| Functionality cookies | These are used to recognise you when you return to our App. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region). By using this App, you agree to our placement of functionality cookies. |
You will be given a chance to opt-in to unnecessary cookies. Please see section B, clause 5, “How to manage cookies” below for more details. Further description of the above-mentioned cookies are as follows:
Strictly Necessary Cookies
We use the following strictly necessary cookies:
| Description | Purpose |
| accessToken (HTTP Cookie) | This is an access token, used for token-based authentications. It allows the server to recognise and authenticate the user for each request without the need for maintaining session state on the server side. |
| refreshToken (HTTP Cookie) | Allows the user to request new access token from the server when the current accessToken expires, which will enable seamless session refresh without requiring the user to log in again. |
| isFirstTimeLogin (HTTP Cookie) | Confirm whether it is the user’s first-time login. |
| termsVersion (HTTP Cookie) | To track the version of what terms that was agreed by the user. |
| privacyVersion (HTTP Cookie) | To track the version of what privacy policy that was agreed by the user. |
| intiNotification (AsyncStorage) | Remember the click action of notification when this App is closed, and process the action after this App is loaded. |
| Analyticalcookies (Android: AsyncStorage. IOS: Keychain) | To track whether user turns on analytical cookies |
| Functionalitycookies (Android: AsyncStorage. IOS: Keychain) | To check whether user turns on Functionality cookies |
| Cookiesbanner (Android: AsyncStorage. IOS: Keychain) | To track whether to display the “Cookies Setting” pop up or not. |
| Showpromotion (Android: AsyncStorage. IOS: Keychain) | To track whether to display the “Receive Updates & Notifications?” pop up or not. |
| _GRECAPTCHA | To identify bots to protect the website against malicious spam attacks. |
| lqd-gdpr | To track whether a user has consented to a website’s cookie policy in compliance with the GDPR. This ensures the website functions correctly and complies with legal requirements. |
| Encrypted login credentials (Android: AsyncStorage. IOS: Keychain) | It is for system to generate a user account for guest checkout. |
| selectedStore (Local Storage/ AsyncStorage) | Remember the last selected store, and redirect to that store when re-open this App. |
Functionality cookies
We use the following functionality cookies:
| Description | Purpose |
| Message_waybill number (AsyncStorage) | Determine if the notification of that waybill is already showed. |
| Insensitive card details (AsyncStorage) | User can save credit card info for next payment. |
| Email (AsyncStorage) | Preset email used for sending order invoice. |
| initNotification (AsyncStorage) | Remember the click action of notification when this App is closed, and process the action after this App is loaded. |
| First Name and Last Name (AsyncStorage) | Greeting in home page. |
Analytical/performance cookies
We use the following analytical/performance cookies:
| Name | Purpose |
| _ga (HTTP Cookie) | To calculate visitor, session and campaign data for analytics reports of Gnatta, in:Five website and app. |
| _ga_{id} (HTTP Cookie) | To store information about the user’s session on Gnatta, in:Five website and app, and track user interactions with the website for analytics purposes. The “{id}” represents a variable part of the cookie name that is unique to the website. |
| _gid (HTTP Cookie) | To store and update a unique value for each page visited, including Gnatta, in:Five website and app, so as to distinguish different visits to the application on different days. |
| utm_campaign (HTTP Request) | Tracking marketing campaigns with Google Analytics using dynamic link. |
| utm_medium (HTTP Request) | Tracking marketing campaigns with Google Analytics using dynamic link. |
| utm_source (HTTP Request) | Tracking marketing campaigns with Google Analytics using dynamic link. |
| utm_content (HTTP Request) | Tracking marketing campaigns with Google Analytics using dynamic link. |
| cid (Customer ID) (HTTP Request) | Tracking marketing campaigns with Google Analytics using dynamic link. |
| _osl (HTTP Request) | Tracking marketing campaigns with Google Analytics using dynamic link. |
| _fpb (HTTP Request) | Tracking marketing campaigns with Google Analytics using dynamic link. |
| _cpt (HTTP Request) | Tracking marketing campaigns with Google Analytics using dynamic link. |
| _iumenbl (HTTP Request) | Tracking marketing campaigns with Google Analytics using dynamic link. |
| _iumchkactval (HTTP Request) | Tracking marketing campaigns with Google Analytics using dynamic link. |
| _plt (HTTP Request) | Tracking marketing campaigns with Google Analytics using dynamic link. |
| _uit (HTTP Request) | Tracking marketing campaigns with Google Analytics using dynamic link. |
| _cpb (HTTP Request) | Tracking marketing campaigns with Google Analytics using dynamic link. |
| _ga_* | To store and count pageviews of in:Five’s website. |
| _gat_gtag_UA_* | To throttle the request rate – limiting the collection of data on high traffic sites. |
4. The Cookies We Set
– Login related cookies: We use cookies when you are logged in to prevent you from having to log in every single time you visit a new page. These cookies are typically removed or cleared when you log out to ensure that you can only access restricted features and areas when logged in.
– Orders processing related cookies: This App offers e-commerce or payment facilities and some cookies are essential to ensure that your order is remembered between pages so that we can process it properly.
– Preferences cookies: In order to provide you with a great experience on this App we provide the functionality to set your preferences for how this site runs when you use it. In order to remember your preferences, we need to set cookies so that this information can be called whenever you interact with a page affected by your preferences.
– Third Party Cookies: In some special cases we also use cookies provided by trusted third parties, including but not limited to the following:
– Google Analytics: for helping us understand how you use this App and ways that we can improve your experience. These cookies may track things such as how long you spend on this App and the pages that you visit so we can continue to produce engaging content. For more information on Google Analytics cookies, please visit the official Google Analytics page.
– Meta Pixel: for helping us understand how you use this App and what actions you perform on this App so we can improve your experience. These cookies may track things such as your advertising preferences and deliver, measure and improve the relevancy of our ads. For more information on Meta Pixel cookies, please visit the official Meta page.
5. How to manage cookies
Before this App places cookies on your device, you will be presented with a message bar requesting your consent to set those cookies. By giving your consent to the placing of cookies, you are enabling us to provide a better experience and service to you. You may, if you wish, deny consent to the placing of cookies; however certain features of this App may not function fully or as intended.
You can choose to enable, disable or delete cookies in your account setting. For further details, please see the help menu in account setting. However, if you disable or delete cookies, you may lose any information that enables you to access this App more quickly and efficiently, including, but not limited to, personalisation settings.
It is recommended that you ensure that your operation system is up-to-date and that you consult the help and guidance provided by the developer of your device if you are unsure about adjusting your privacy settings.
C. General and contact information
The below applies to the Policy. Please read carefully.
Topics:
1. Links to other websites
2. Changes to our Policy
3. Changes of business ownership and control
4. Transfer of rights
5. How to contact us
6. How to contact the appropriate authority How do we use cookies?
1. Links to other websites
This App may, from time to time, provide links to other websites. This Policy does not extend to your use of such websites. We have no control over such websites and are not responsible for their content. You are advised to read the privacy and cookies policies of other websites prior to using them.
2. Changes to our Policy
We reserve the right to change this Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on this App with clickwrap agreement when you launch this App. You are deemed to have accepted the terms of the Policy on your first use of this App following the alterations.
3. Changes of business ownership and control
We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Shoalter Automation (UK) Limited. Data you provide will, where it is relevant to any part of our business so transferred, be transferred along with that part of the business and the new owner or newly controlling party will, under the terms of this Policy and in accordance with the Data Protection Laws, be permitted to use the Data for the purposes for which it was originally supplied to us.
4. Transfer of rights
You may not transfer any of your rights under this Policy to any other person.
We may transfer our rights under this Policy where we reasonably believe your rights will not be affected.
If any court or competent authority finds that any provision of this Policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Policy will not be affected.
Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
This Policy will be governed by and interpreted according to the laws of England and Wales. All disputes arising under the Policy will be subject to the exclusive jurisdiction of the English and Welsh courts.
5. How to contact us
If you have any questions about our Policy, the Data we hold on you, or would like to exercise any of your data protection rights, please do not hesitate to contact us via email at privacy@in-five.co.uk. Please note that we will need to receive satisfactory proof of your identity should you exercise your rights.
6. How to contact the appropriate authority
If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.
Last updated: September 2024