Introduction

This Privacy Policy sets out how Tail Offers Ltd (“Tail”) collects and processes data about
you as part of Tail’s application and service (together the “Service”).

In summary, Tail accesses your transaction data for purchases you make with the credit and
debit cards associated with your bank account. This is in order to offer you cashback every
time you shop at our partner retailers. Due to the continuous evolution of the Service, we may
extend offers and services we provide to you from time to time and may need to change our
Privacy Policy correspondingly to reflect these changes.

Categories of Personal Data we collect

We may collect the following information about you:

  • Your name, date of birth, email address, phone number and payment identifier(s)
    you want to associate with your account.
  • Details of transaction data from purchases that you make, using the credit or debit
    card(s) you have associated with your account, from retailers. This will include
    amount, time and date, and location of that particular transaction.
  • Details of which offers you click on within the Service, and when.
  • We may also ask you to complete feedback that we use for research purposes,
    although you do not have to respond to them.
  • If you contact us, we may keep a record of that correspondence for administrational
    and/or legal purposes.
  • We may collect private information that you grant us permission to collect, and
    public information, from third party websites such as, but not limited to, Facebook,
    Google and Twitter. If we decide to do so, the first time we request access to private
    information from a third party website, that website will ask your permission to
    allow us to access the private information. You have the right to revoke access to the
    Service via your associated accounts with those third party websites.

The purposes of processing your Personal Data

We process your personal data for the following reasons:

  • In order to provide the Service to you, meaning that we will view your transaction
    data in order to present you with offers at our partner retailers, which may be
    general or tailored to your location and prior purchases.
  • To offer you cashback every time you shop at our partner retailers. Due to the
    continuous evolution of the Service, we may extend offers and services we provide
    to you from time to time and may need to change our Privacy Policy correspondingly
    to reflect these changes.
  • For certain purchases, including e.g. venue bookings, we may have to introduce you
    directly to the venue to facilitate the booking. In that case, you will be notified
    within the app.
  • We keep information that we collect about your purchases and related information
    (including amounts, place and time) and use it for aggregated and anonymised
    statistical analysis. This is in order to improve the matching of partner retailers
    to you based on your spending profile (although please note the retailer
    will never be able to identify you specifically and will only see your spending
    preferences in an aggregated way).
  • We keep information about your other transaction data such as from retailers that
    are not currently on the Tail Offers platform. This is for the purpose of customising
    your content and understanding your preferences, as well as to improve the matching of
    partner retailers to you. All such data will be anonymised upon collection. We
    explicitly request your consent to sharing the data when you first sign up to Tail
    Offers.
  • We aggregate information that we have collected about you with other users’
    information (including e.g. specific spending behaviour) to create aggregated data
    sets – which don’t reveal anything about you individually that help us, retailers and
    other partners of ours to understand anonymised consumer behaviour.
  • We may send you notices via e-mail, regular mail, or alerts within the Service.

The Legal Basis for Processing your data

We rely on your consent for processing the above categories of your data. Your grant us
permission to process your data when you sign up via our app and specifically accept the
processing of your data in order to provide you with the Service.

Where we obtain your Personal Data from

When signing up, you approve the Service obtaining access data associated with the
respective bank account you use to sign up to the Service. We obtain your personal data via
access to that bank account. We may also obtain private information that you grant us
permission to collect, and public information, from third party websites such as, but not
limited to, Facebook, Google and Twitter. You have the right to revoke access to the Service
via your associated accounts with those third party websites.

IP addresses and cookies

We may collect information about your mobile device, including where available your IP
address, operating system and browser type, for system administration, to optimise the
quality of the Service and to report aggregate information to our partners.

For the same reason, we may obtain information about your general internet usage by using
a cookie file which is stored on your mobile device. A cookie is a text-only string of data that
is entered into the cookie file or ‘memory’ of the browser on your computer. It will typically
contain the name of the domain from which the cookie has come, the ‘lifetime’ of the
cookie, and a value, usually a randomly generated unique number. Cookies help us to
improve the Service and to deliver a better and more personalised service. They enable us:

  1. to estimate our audience size and usage pattern;
  2. to store information about your preferences, and so allow us to tailor our services
    according to your individual interests;
  3. to speed up your searches; and
  4. to recognise you when you return to our services.

All browser technologies enable you to manage the cookies in the cookie folder of your
browser. This means that you can either delete cookies from your cookie folder once you
have finished your visit at our services or you can set your preference with regard to the use
of cookies before you begin surfing our website – for example you may be asked to re-enter
some information e.g. your name and password to use some pages.

Recipients of your Data

We may disclose your personal information to any current or future member of the Tail
Offers group of companies, which might entail subsidiaries or holding companies.

We may disclose usage patterns and other analytics on aggregated data sets (these data
sets aggregating your and other users’ information) to retailers and banks we work with.

We may disclose your personal information to third parties:

  1. In the event that we sell or buy any business or assets, in which case we may disclose
    your personal data to the prospective seller or buyer of such business or assets, on
    the condition that (i) we will limit any such disclosure the extent necessary for the
    purpose of the transaction, and (ii) they do not use it prior to such purchase or sale
    for any purpose other than the evaluation of the purchase or sale;
  2. If Tail or substantially all of its assets are acquired by a third party, in which case
    personal data held by it about its customers will be one of the transferred assets;
    and/or
  3. If we are under a duty to disclose or share your personal data in order to comply
    with any legal obligation, or in order to enforce or apply the Terms and/or other
    agreements; or
  4. To protect the rights, property, or safety of Tail Offers Ltd, our customers, or others.
    This includes exchanging information with other companies and organisations for
    the purposes of fraud protection and credit risk reduction.
  5. For certain purchases, including e.g. venue bookings, we may have to introduce you directly
    to the venue to facilitate the booking. In that case, you will be notified within the app.

We do not currently transfer to, or store your data at, a destination outside of the European
Economic Area.

The Service may, from time to time, contain links to and from the websites of our partner
networks, advertisers and affiliates. If you follow a link to any of these websites, please note
that these websites have their own privacy policies and that we do not accept any
responsibility or liability for these policies. Please check these policies before you submit
any personal data to these websites.

Storage of your Data

Your data is stored on servers in Ireland.

Unfortunately the transmission of information via the internet is not completely secure. We
will do our best to protect your personal data, however we cannot guarantee without doubt
the security of your data transmitted to the Service; any transmission is at your own risk.
Once we have received your information, we will use strict procedures and bank level
encryption to prevent unauthorised access.

Unless we are required to retain your personal data by law, we will delete your personal
data (other than data that has been anonymised and aggregated for statistical purposes)
within 30 days of you notifying us that you no longer wish to use the Service.

Automated Processing/Profiling

In order to provide you with a more tailored Service and offers more relevant to you, we will
process and evaluate your transaction data in regards to the type and location of prior
purchases you have made as well as location data of app usage.

Data Controller Details

For the purpose of applicable data protection legislation (including but not limited to the
General Data Protection Regulation (Regulation (EU) 2016/679)), the company responsible
for your personal data is Tail Offers Ltd (a company registered in England and Wales under
company No. 10008580) and can be contacted at {{ partner_data.partner_address }}
or at privacy@tail.cash .

Your rights

  • In certain circumstances, you have the right to request from us access to, amendment or
    deletion of your personal data.
  • In certain circumstances, you also have the right to restrict our processing of your
    personal data, to object to our processing your personal data and the right to request
    that we transfer your personal data to a third party.
  • Where you have consented to us processing your data, you have the right to withdraw
    such consent at any time, without affecting the lawfulness of processing based on
    consent before its withdrawal.
  • You have the right not to be subject to a decision based solely on automated processing,
    including profiling, which produces legal effects or similarly significantly affects you.
  • You have the right to lodge a complaint with our Supervisory Authority, the ICO
    (https://ico.org.uk/concerns/).

Please inform us if you would like to exercise any of the above rights by contacting us at
privacy@tail.cash.

Changes to our privacy policy

We may need to change our Privacy Policy from time to time when we add or further
develop certain features or parts of the Service.

We may also revise this Privacy Policy at any time for security, legal, best practice or
regulatory reasons by amending this page.

You are expected to check these terms from time to time to take notice of any changes we
have made, as they are binding on you, however data taken before any changes will not be
affected unless we have your individual permission.

Tail Offers Ltd is registered with the Financial Conduct Authority under the Payment Services Regulations 2017 as an account information services provider (FRN: 791697). Tail is registered in England and Wales (No. 10008580) with its registered office at 15 Belgrave Square, London  SW1X 8PS.