App Privacy Policy

At SPAR we are committed to protecting and respecting your privacy.

The Legal Stuff

Introduction

This policy (together with our SPAR Rewards App Terms of Use (App Terms) and any additional terms of use incorporated by reference into the App Terms, together SPAR Rewards Membership Terms) applies to your use of:

The SPAR Rewards App (which was last updated on [DATE]) mobile application software (App), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).
Any of the services accessible through the App (Services) including those that are available on the SPAR Rewards website at [INSERT URL]. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

This policy is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can download a pdf version of the policy here: [LINK].

IMPORTANT INFORMATION AND WHO WE ARE
THE DATA WE COLLECT ABOUT YOU
HOW YOUR PERSONAL DATA IS COLLECTED
HOW WE USE YOUR PERSONAL DATA
DISCLOSURES OF YOUR PERSONAL DATA
INTERNATIONAL TRANSFERS
DATA SECURITY
DATA RETENTION
YOUR LEGAL RIGHTS
GLOSSARY
DESCRIPTION OF CATEGORIES OF PERSONAL DATA

Important information and who we are

SPAR (UK) Limited of Mezzanine Floor Hygeia Building, 66-68 College Road, Harrow, Middlesex, HA1 1BE (we, our, or us) are committed to protecting and respecting your privacy.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us when, as a Consumer you engage with us and our regional distribution centres using the SPAR Rewards App or when you become a member of SPAR Rewards. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

This policy is intended to be compliant with the retained version of the EU General Data Protection Regulation 2016 (UK GDPR) and the Data Protection Act 2018 (the Data Laws).

For the purpose of the Data Laws, we are the data controller. This means that we are responsible for determining when, why and how we process your personal data.

We have appointed a Data Manager who has overall responsibility within SPAR (UK) Ltd for data protection. The Data Manager may be contacted by emailing dpm@spar.co.uk or by writing to: Data Manager, SPAR (UK) Ltd of Mezzanine Floor Hygeia Building, 66-68 College Road, Harrow, Middlesex, HA1 1BE.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

This version was last updated on [DATE]. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by SMS, email or when you next start the App or log into your SPAR Rewards Account. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or SPAR Rewards.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Third party links

The App and our website may, from time to time, contain links to and from the websites of our suppliers, partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.

The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as follows:

Identity Data.
Contact Data.
Transaction Data.
Device Data.
Content Data.
Profile Data.
Usage Data.
Marketing and Communications Data.
Location Data

We explain these categories of data here.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How is your personal data collected?

We will collect and process the following data about you:

Information you give us. This is information (including Identity, Contact, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App or on the SPAR Rewards webpage (together Our Sites), or by corresponding with us (for example, by email, chat or by filling in a SPAR Rewards application with the assistance of one of our store colleagues). It includes information you provide when you apply for membership of SPAR Rewards, download the App, enter a competition, promotion or survey, use any voucher, or reward and when you report a problem with the App, SPAR Rewards, or any of Our Sites. If you contact us, we will keep a record of that correspondence.
Information we collect about you and your device. Each time you visit one of Our Sites or use the App we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy for further details.
Location Data. We also use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your browser or account settings.
Information we receive from other sources including third parties. We will receive personal data about you from various third parties as set out below:
- Our store operators and regional distribution centres;
- Device Data from the following parties:

analytics providers such as Google based outside the UK; and

advertising networks

Contact, and Transaction Data from providers of technical, payment and delivery services [such as [NAME] based [inside OR outside] the UK];
[ANY OTHER WAYS YOU COLLECT PERSONAL DATA].

Cookies

We use cookies and/or other tracking technologies to distinguish you from other users of the App, Our Sites or the distribution platform (Appstore) and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse any of Our Sites and also allows us to improve the App and Our Sites. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.

How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

Where you have consented before the processing.
Where we need to perform a contract we are about to enter or have entered with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Purposes for which we will use your personal data

Purpose/activity	Type of data	Lawful basis for processing
To install the App and register you as a new App user	Identity Contact Device	Your consent
To deliver Services including the provision of SPAR Rewards	Identity Contact Transaction Device Marketing and Communications Location	Your consent Performance of a contract with you Necessary for our legitimate interests (to offer you promotions, offers and rewards based on your transaction history)
To manage our relationship with you including notifying you of changes to the App or SPAR Rewards	Identity Contact Profile Marketing and Communications	Your consent Performance of a contract with you Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services) Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
To enable you to participate in a prize draw, competition or complete a survey or to utilise any SPAR Rewards member offers, deals, promotions or rewards.	Identity Contact Transaction Device Profile Marketing and Communications	Your consent Performance of a contract with you Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business and to allow us to offer you offers, deals promotions and rewards which we think may be of interest to you)
To administer and protect our business and this App including troubleshooting, data analysis and system testing	Identity Contact Device	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
To deliver content and advertisements to you To make recommendations to you about goods or services which may interest you To measure and analyse the effectiveness of the advertising we serve you To monitor trends so we can improve the App	Identity Contact Transaction Device Content Profile Usage Marketing and Communications Location	Consent Necessary for our legitimate interests (to develop our products/Services and grow our business)
To help you find SPAR stores	Location	Your Consent Necessary for our legitimate interests (enabling you to find local stores)

Disclosures of your personal data

Your personal data will only be disclosed to those of our employees or workers that have a need for such access for the purpose for which it was collected. Your personal data will not be disclosed to any other individuals or other entities except as further detailed below.

We may share your personal information with any member of the SPAR group of companies, in order respond to your queries or complaints or for the efficient administration of the App and SPAR Rewards. This may include sharing your personal data with the following companies who operate as part of the SPAR group of companies:

CJ Lang & Son Ltd – Scotland region;
James Hall & Co Ltd - North of England region;
AF Blakemore & Son Ltd - Central and South East England and Wales region;
Appleby Westward Group Ltd - South West England region;
Henderson Wholesale Ltd - Northern Ireland region.

Each of the above companies will have their own privacy policies that explain how they use your personal data. It is important that you read these privacy policies which can be accessed by clicking the names above.

We may also share your information with suppliers in respect of specific promotions.

On occasion, we need to hire other companies to help us to serve you better and in some of these cases we may need to share personal data that is necessary to perform tasks for us, such as marketing agencies.

We may also share your personal data with third parties:

Where it is necessary for the performance of our contract with you, including where you have asked us to do so or where we need to take steps to enforce any contract which may be entered into between us.
Where we are under a legal duty to do so in order to comply with any legal obligation.
In order to protect the rights, property or safety of our business, our employees and workers, customers, suppliers and others. This includes exchanging information with other companies and organisations for the purposes of fraud prevention and credit risk reduction.
If we or substantially all of our assets are acquired by a third party, in which case personal data that we hold about our customers will be one of the transferred assets.

We require all third parties that process personal data with our permission and on our behalf to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

We do not generally transfer your personal data outside the UK. However, whenever it is necessary for us to do so, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
Where we use certain service providers, we may use specific contracts approved by the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

Data security

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password for your SPAR Rewards account or for the App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

We will collect and store personal data on your Device using application data caches and browser web storage (including HTML5) and other technology.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see ‘Your legal rights’ below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

In the event that you do not use the App for a period of 12 months then we will treat the account as expired and your personal data may be deleted.

Your legal rights

Under certain circumstances, you have a number of individual rights in connection with your personal data. Those rights are as follows:

Right to be informed: You have the right to be informed of the personal data we collect about you and the reasons for this. This Policy seeks to provide this information.

Right to access: You have the right to request a copy of the personal data we hold about you and to check that we are lawfully processing it.

Right to rectification: You have the right to correct any inaccurate or incomplete personal data we hold about you.

Right to erasure: You may ask us to delete your personal data where there is no good reason for us continuing to process it or you have successfully objected to our processing (see below), where we are unlawfully processing or are required to delete your personal data by law. This is a limited right and we may not agree to your request if we consider that we have a compelling legal reason for continuing to process your personal data.

Right to object: You have the right to object to our processing of your personal data where we are relying on a legitimate interest and you consider that your rights and freedoms override such interests. You have the right to object where we are processing your personal data for direct marketing purposes. In some instances we may be able show that we have compelling legal reasons for continuing to process your personal data notwithstanding your objection.

Right to restrict: You can ask us to suspend the processing of your personal data: (1) if you want us to establish the data’s accuracy; (2) where our use of such data is unlawful but you do not want us to erase it; (3) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (4) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Right to Data Portability: You have the right to request the transfer of the personal data we hold for you to a third party in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Right to withdraw consent at any time: Where we rely on consent as a legal basis for processing your personal data, you have the right to withdraw that consent at any time. You can withdraw your consent by emailing the Data Manager at SPAR (UK) Ltd and asking us. The email address is set out at the end of this policy.

You will not have to pay a fee to exercise any of these individual rights unless we consider that your request is clearly unfounded, repetitive or excessive. We may also refuse to deal with your requests in these circumstances.

We may seek to verify your identity first before responding to any of your individual requests. You also have the right to ask us not to continue to process your personal data for marketing purposes.

Changes to our privacy policy

We may revise this policy at any time by amending this page. Any changes we may make to our privacy policy in the future will be posted on our website and, where appropriate, notified to you by e-mail or sent out to you in hard copy. Please check back frequently to see any updates or changes to our privacy policy.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to the Data Manager, SPAR (UK) Limited, Mezzanine Floor Hygeia Building, 66-68 College Road, Harrow, Middlesex, HA1 1BE OR dpm@spar.co.uk.

Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) at www.ico.org.uk. We would however appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Glossary

Lawful basis

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Description of categories of personal data

Identity Data: first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender.

Contact Data: address, email address and telephone numbers.

Transaction Data: includes details about SPAR Rewards offers, promotions and vouchers which you have downloaded and used as well as details of the products which you have purchased from SPAR stores and the location of the SPAR stores from which you have made those purchases.

Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use and time zone setting.

Content Data: includes information stored on your Device, including login information.

Profile Data: includes your username and password, in-App purchase history, your interests, preferences, feedback and survey responses.

Usage Data: includes details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, traffic data and other communication data, and the resources that you access.

Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Location Data: includes your current location disclosed by GPS technology.

Save with SPAR

Save with SPAR

Products

Find a SPAR with a Post Office

Post Office

In-Store

Food To Go

Easy Nachos Recipe

Easy Nachos Recipe

Recipe Categories

Nurture our Neighbourhoods

Featured

Community Cashback

Who we are

Featured News

AERO Strawberry

Lawful basis