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Effective
Date: 25th May 2018
This
Privacy Statement explains how Groupon International Limited and our European
Affiliates collect, control, process, and use information about you (which we
call “personal data”).
When we say
“Groupon International”, “us”, “our”, or “we”, we mean Groupon International
Limited. Groupon International is the
operator of the Groupon marketplace. It
provides platforms where our EU Affiliates and other unaffiliated third-party
sellers (collectively “Sellers”) can list offers for vouchers, deals, goods,
getaways, and other offerings.
Our
European Affiliates (“EU Affiliates”) include: MyCityDeal Limited (UK),
Groupon-Citydeal Limited (Ireland), Groupon France SAS (France), Groupon
SPRL/Groupon BVBA (Belgium), Groupon Netherlands B.V., Groupon GmbH (Germany),
Groupon S.r.l. (Italy), Groupon Spain S.L.U. (Spain), Groupon Sp. z.o.o
(Poland), Groupon Goods Global GmbH and Groupon International Travel GmbH (both
located in Switzerland). European
Affiliates collect, process, and use your personal data as necessary to
facilitate the sale of vouchers, deals, goods, and getaways. Our EU Affiliates also comply with this
Privacy Statement.
When we
talk about the “Site”, we mean our platforms, which include our websites,
mobile applications, communications we send or services we provide, social
networking sites, or any other websites we offer that link to or reference this
Privacy Statement.
Change
We
routinely update this Privacy Statement to clarify our practices and to reflect
new or different privacy practices, such as when we add new services,
functionality, or features to the Site. If we make any material changes we will
notify you, either by email (sent to the email address specified in your
account), by means of notice on the Site or by using other methods. You can
determine when this version of the Privacy Statement was adopted by referring
to the “Effective Date” above.
You
understand that your continued use of the Site after we send a notice about our
changes to the Privacy Statement means that the collection, control,
processing, and use of your personal data is subject to the updated Privacy
Statement. If you object to any changes,
you may modify your account settings or close your account as described below.
1. Personal Data We Collect
We will
collect the following personal data when you interact with the Site:
●
Authentication and
identification information (e.g. your name, email address, and password). This
information is necessary to set up and log you into your account. If you don’t
provide it, we may not be able to provide our services to you;
●
Basic personal details (e.g.
your name, date of birth, and nationality);
●
Contact details (e.g. your
postal address, telephone number, and email address). We may need some of this
information to deliver products to you, such as your postal address, and won’t
be able to carry out these services if you don’t provide it;
●
Payment details (e.g. your
credit card details or payment tokens from third party payment providers like
PayPal). We use these to process your order, and won’t be able to take payment
from you or give refunds if you don’t provide it; and
●
Information about your
contacts with Groupon (e.g. call recordings, instant messages on our site, and
user generated content).
We will
also automatically collect personal data when you interact with the Site
through your computer, mobile device, or other device. This personal data
includes the following:
●
Analytics data (e.g.
information about app downloads, app and web page histories), which may include
data collected from cookies and other types of device identifiers;
●
Profile inputs (e.g. page
and deal views on the site, click information and information about the website
you clicked to our Site from). This may include data about your location. With
respect to geolocation information collected from your mobile device, we will
only collect this where you have provided consent; and
●
Device details (e.g. MAC
address, IP address, bluetooth data and advertising identifiers).
We also
receive personal data and other online and offline information from third parties with whom we conduct
business, such as merchants, co-marketers, distributors, resellers, and other
companies or organizations with whom we enter into agreements to support our
business and operations, including advertising partners (collectively
“Business Partners”).
The
personal data we receive from Business Partners includes demographic, location,
and purchase information. We and will only receive this personal data when the
Business Partner states that they are
legally permitted to do so to share it with us. We use this information i to
better understand your deal preferences and how our merchants perform so we can
provide you with a better Groupon experience.
We will
collect the personal data described above at various stages in your
relationship with us when you:
●
Register, subscribe,
authorise the transfer of, or create an account with us;
●
Open or respond to emails or
messages from us;
●
Provide information to
enroll or participate in programs provided on behalf of, or together with
Sellers and Business Partners, with your consent or as necessary to provide
services you have requested;
●
Visit any page online that
displays our ads or content;
●
Purchase products or
services on or through the Site from Sellers;
●
Connect, log-in, or link to
the Site using social networking tools; and
●
Post comments to the online
communities sections of the Site.
We also
create profiles about you based on the personal data you provide to us or that
is collected from you, as described above. We do this to market offers to you
we think you would be interested in buying. The contents of that profile
include:
●
Account
details. For example, we create a permanent URL to your account page
which may include your name. We also generate tokens to remember your
subscription and purchase histories, and any loyalty numbers you may have
obtained;
●
Marketing
segment information. For example, if you
purchase products or services related to wellness and beauty, we may infer that
you are interested in these types of products, or if you purchase Groupon
Getaways deals we may infer that you are a frequent traveler;
●
Audience
information. We create audiences based on parameters such as
gender, age, and location (e.g. males aged 25-35 in your city), and if your
personal data matches those audiences, you’ll be assigned to it. This is to
help you receive relevant offers; and
●
Activity
information. Based on your interactions with communications,
we’ll generate personal data about how many communications you like to receive,
so that we don’t send you more than are useful to you.
2. Your Choices
You can
manage the types of personal data you provide to us and can limit how we
communicate with you. At the same time, we think that the more you tell us
about yourself and what you like, the more relevant and valuable your
experience with our Site and services will be.
You can
manage your email, push notification, location information and subscription
notification preferences by logging into your account through the Site or by
adjusting the settings in our mobile application:
●
Push
notifications and location information. Your device
and the Groupon mobile app provide you with options to control push
notifications and how and when we collect your geolocation. You can disallow
our use of certain location data through your device or browser settings, for
example, by disabling “Location” services for the Groupon application in
Apple’s iOS and Android privacy settings, or by disabling “Location” services
for your device;
●
Subscriptions. You can also manage your
subscriptions by following subscription management instructions contained in
any commercial emails that we send you. You may choose to subscribe to some
types of messages, and may choose not to subscribe to, or to unsubscribe from,
others. You may update your subscription preferences at any time. Even if you
decide not to subscribe to, or to unsubscribe, from promotional email messages,
we may still need to contact you with important transactional information
related to your account and your purchases from Sellers. For example, even if
you have unsubscribed from our promotional email messages or push
notifications, we will still send you confirmations when you make purchases on
the Site;
●
Cookies. You can manage how your
browser handles cookies. You may also manage how your mobile device and mobile
browser share information on and about your devices with us, as well as how
your mobile browser handles cookies. Please refer to our Cookies Policy for
more information;
●
Social
networking. You may also manage
sharing certain personal data with us when you connect with us through social
networking platforms or applications. Please refer to Section 8 below and also
the privacy policy and settings of the social networking website or application
to determine how you may adjust our permissions and manage the interactivity
between us and your social networking account or your mobile device.
3. Your Rights
You can
access, update, rectify, and delete your personal data which makes up some of
your profile by logging into your account or contacting us here. Keeping your
personal data current helps ensure that we can respect your preferences and
offer you the goods and services that are most relevant to you.
In
accordance with applicable law, you may (i) request access to any personal data
we hold about you; (ii) request that it be updated, rectified, deleted or
blocked; (iii) request that we delete personal data we hold about you; (iv)
request that we restrict our processing of your personal data; and (v) request
that we provide you or a third party with a copy of certain personal data about
you (that is referred to as the right of
“data portability”). You can also object to any of our uses of your
personal data described in this policy, including our marketing activities.
4. How We Use Information
We control
and process the personal data you provide to us, which we collect from other
sources, and which we generate to:
●
Create your account when you
sign up and log you in, which is necessary for us to provide our services to
you in accordance with the Terms of Use;
●
Operate, maintain, and
improve the Site by analyzing how you and our other customers use and interact
with it. This is to meet our legitimate business interests in providing the
Site and ensuring that it provides the best experience for our customers;
●
Validate, facilitate, and
prevent fraudulent purchases. This may include processing orders for vouchers
and other goods and services, payment verification, and verifying that vouchers
redeemed by customers are valid. This is necessary to meet our contractual commitments
to you set out in the Terms of Use;
●
Carry-out marketing, which
may involve:
o
Establishing and analyzing
individual and group profiles and customer behavior, in order to determine your
or others interest in certain types of offers, products, and services. We do
this by analyzing your interactions with the Site and your other personal data
to determine what your interests are, and what sorts of products and services
people with similar interests also buy, which helps us understand what products
and services you may be interested in viewing. This is to meet our legitimate
interests in understanding the types of products and services our customers are
interested in, and to provide the most relevant products to you and our other
customers;
o Showing relevant offers and advertising. We will use the profiles described above to create advertising for our products that will be displayed on relevant third-party sites. We do this to meet our legitimate interests in showing you products which may be relevant to you, and you can opt out of seeing these types of ads as described in our Cookies Policy;
o
Sending you relevant direct
marketing messages and other communications via email or push notifications on
mobile devices, including, with your consent, using your location data to
notify you of tailored location-based deals. We will either send these messages
on the basis that you have consented to receiving them or, where permitted by
applicable law, to meet our legitimate interests in showing you which of our
products and services are relevant to you; and
o
Analyzing advertising
effectiveness, which may involve analyzing the advertising campaigns our
customers choose to interact with most often. This is to meet our legitimate
interests in understanding which types of advertising campaigns are more or
less effective than others.
●
Answer your questions and
respond to your requests, for example in the context of customer service. This
is to meet our contractual commitments to you in the Terms of Use where these questions or requests are part of the purchase process or to comply
with legal obligations (such as allowing you to exercise your rights as
described above), and in other cases to meet our legitimate interests in
providing a good service to our customers;
●
Send you reminders,
technical notices, updates, security alerts, support and administrative
messages, service bulletins, and requested information, including on behalf of
Business Partners, EU Affiliates, or other Sellers. This is to meet our
legitimate interests in managing our relationship with you effectively;
●
Administer rewards, surveys,
sweepstakes, contests, or other promotional activities or events, in order to
meet our contractual commitments to you set out in the terms and conditions of
those promotional events;
●
Manage our everyday business
needs, such as administration of the Site, forum management, fulfillment,
analytics, fraud prevention, and enforcement of our corporate reporting
obligations and Terms of Use or to comply with the law; and
●
Comply with our legal
obligations, resolve disputes, and enforce our agreements. We do this where
necessary to comply with legal obligations to which we are subject, or to meet
our legitimate interests in enforcing our legal rights and resolving disputes
or verifying payments and preventing fraud.
5. When and Why We Disclose
Personal Data
We share
your personal data as follows:
●
with your consent;
●
with EU Affiliates and other
Groupon entities within and outside of the European Economic Area, including,
without limitation, Groupon, Inc. which has its registered offices at 600 West
Chicago Avenue, Chicago, Illinois 60610, USA, who will process your personal
data only in accordance with our instructions and for the purposes set out in
this Privacy Statement;
●
with unaffiliated
third-party Sellers and Business Partners , so they can sell, deliver, and
provide the products or services purchased to you (e.g. to deliver products to
you, or to provide a Getaways provider with your details so they can confirm
reservations). We share personal data with unaffiliated third-party Sellers and
Business Partners in order to meet our contractual obligations to you, and they
are not permitted to use your personal data in any way other than for selling,
delivering, and/or providing the products or services purchased by you;
● with third parties that provide tools and services to help us better understand your deal preferences, so that we can show you advertisements for Groupon vouchers, goods, or services on third party websites which are more suited to your interests and tastes. Those third parties may also use your personal data to match you with their existing customer base. You can stop our use of these tools in the ways described in our Cookies Policy;
● with third parties, to send you survey emails on our
behalf, provided you have consented to receive such emails;
● to report or collect on debts owed to Sellers or other Business Partners;
●
as necessary to perform
contractual obligations towards you with Sellers or Business Partners to the
extent you have purchased or redeemed a Groupon voucher, goods, or services
offered by them or participated in an offer, rewards, contest or other activity
or program sponsored or offered through us or the Sellers on behalf of a
Business Partner;
●
to a subsequent owner,
co-owner, or operator of one or more of the Sites or any portion or operation
related to part of one or more of the Sites;
●
in connection with a
corporate merger, consolidation, or restructuring, the sale of substantially
all of our stock and/or assets, or other corporate change, including, without
limitation, during the course of any due diligence process;
●
to comply with legal orders
and government requests, or as needed to support auditing, compliance, and
corporate governance functions, where this is necessary to comply with these
legal obligations;
●
to combat fraud or criminal
activity, and to protect our rights or those of our EU Affiliates, Sellers, or
Business Partners, and users, or as part of legal proceedings affecting us
and/or our EU Affiliates, as it is in our legitimate interests to prevent fraud
and protect these rights; or
●
in response to a subpoena,
or similar legal process, including to law enforcement agencies, regulators,
and courts, to the extent this is necessary to comply with such legal
obligations.
We
encourage our unaffiliated third-party Sellers and Business Partners to adopt
and post privacy policies. However, while we share personal data with Sellers
and Business Partners only for the above-mentioned purposes, their subsequent
processing and use of personal data obtained through us and our European
Affiliates is governed by their own privacy policies and practices and is not
under our control (except for the use and processing by Sellers and Business
Partners providing services to us, as described above). Where possible, we
contractually restrict how our Sellers and Business Partners, including
merchants, use your personal data and aim to ensure they do not use it for any
purposes which are incompatible with those set out in this privacy statement.
In a number
of the cases set out above, we will transfer your personal data to a country
located outside the European Economic Area that may not be considered as
providing the same level of protection for personal data under European law. In
such cases, we put in place appropriate safeguards, including contractual
commitments approved by the European Commission, on recipients of the data, to
ensure that there is adequate protection for your personal data. For more
information about the safeguards in place and to view a copy of such
safeguards, please contact us using the details below.
6. Security of Personal Data
We have
implemented an information security program that contains administrative,
technical and physical controls that are designed to safeguard your personal
data, including industry-standard encryption technology. However, no method of transmission over the Internet, or method of electronic
storage, is 100% secure. Therefore, we cannot guarantee its absolute security.
7. Retention of Personal
Data
We will retain your personal data for as long as your account is
active or as needed to provide you services. If you close your account, we will
retain your personal data for a period where it is necessary to continue
operating our business effectively, to maintain a record of your transactions
for financial reporting purposes or fraud prevention purposes until these
purposes no longer exist, and to retain as necessary to comply with our legal
obligations, resolve disputes, and enforce our agreements.
8. Social Networks
Social
Community Areas
You may
access the Site through, or the Site may contain connections to, areas where
you may be able to publicly post information, communicate with others such as
discussion boards or blogs, review products and merchants, and submit media
content. Prior to posting in these areas, please read our Terms of Use carefully. All of the
information you post may be accessible to anyone with Internet access, and any
information you include in your posting may be read, collected, and used by
others. For example, if you post your email address along with a public
restaurant review, you may receive unsolicited messages from other parties. You
should avoid publicly posting sensitive information about you or others.
Connecting
through Social Networks
We offer
social networking users the opportunity to interact with friends and to share
on social networks. If you are logged into both the Site and a social network,
when you use the Site’s social networking connection functions, you will
connect your social network account with your Groupon account (this happens
automatically, if the email addresses match). If the email addresses do not
match, we ask you if you want to link them and you must validate that you control
the accounts by logging in to your social network account. If you are already
logged into the Site but not into your social network site, when you use the
Site’s social network connection functions, you will be prompted to enter your
social network website credentials or to sign up for the social network.
If you are
not currently registered as a Groupon user and you use the Site’s social
network connection functions, you will first be asked to enter your social
network credentials and then be given the option to register and join Groupon.
Once you register with us and connect with the social network, you will be able
to automatically post recent Groupon activity back to your social network.
Please refer to the privacy settings in your social network account to manage
the data that is shared through your account.
When you
use the Site’s social network connection function, you will have the
opportunity to consent to our accessing all of the elements of your social
network profile information that you have made available to be shared (as per
the settings chosen by you in your social network profile) and to use it in
accordance with the social network’s terms of use and this Privacy Statement.
You can withdraw this consent at any time.
9. Privacy Practices of
Third Parties
This
Privacy Statement only addresses the collection, processing and use (including
disclosure) of personal data by us through your interaction with the Site.
Other websites that may be accessible through links from the Site may have
their own privacy statements and personal data collection, processing, use, and
disclosure practices. Our Business Partners may also have their own privacy
statements. We encourage you to familiarise yourself with the privacy
statements provided by these other parties prior to providing them with
information or taking advantage of a sponsored offer or promotion.
10. Contact
Us
If you have any questions or comments about our privacy practices or this Privacy Statement, if you want to make use of any of the above rights, or other rights that you may have in relation to your personal data, please contact us via this form.
. You can
also contact our Data Protection Officer at dpo@groupon.com and can also reach
us via postal mail at the following address:
Groupon
International Limited, ATTN: Data Protection Officer, Lower Ground Floor,
Connaught House, 1 Burlington Road, Dublin 4, 216410 Ireland.
We are committed to working with you to obtain a
fair resolution of any request, complaint, or concern about our use of your
personal data. If, however, you believe that we have not been able to assist
you, you have the right to make a complaint to the data protection authority in
your country of residence or to our Lead Supervisory Authority:
|
By Post: Office of the Data Protection Commissioner Canal House, Station Road Portarlington, Co. Laois R32 AP23 Ireland By Email: |
info@dataprotection.ie