The Cat Track Ltd

Personal data means any information about an individual from which that person can be identified. It does not include anonymised data, where the identity and identifying information has been removed.

While our website is designed for a general audience, we will not knowingly collect any data from children under the age of 16 or sell products to children. If you are under the age of 16, you are not permitted to use or submit your data to the website.

The following groups of personal data are collected:

•Identity Data includes information such as: title, first name, last name, date of birth (optional), occupation, personal description, photo and gender.

•Contact Data includes information such as: email address, billing address, delivery address, location, country, telephone number, loyalty programme membership number, and social media id (if you log in by social media).

•Financial Data includes information such as: payment card details and bank account.

•Transaction Data includes information such as: details of your purchases and the fulfilment of your orders (such as basket number, order number, subtotal, title, currency, discounts, shipping, number of items, product number, single item price, category, tax etc.) payments to and from you and details of other products and services you have obtained from us, correspondence or communications with you in respect of your orders, and details of any rewards and bonuses awarded.

•Technical Data includes information such as: details of the device(s) you use to access our services, your internet protocol (IP) address, login data, your username and password, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform.

•Profile Data includes information such as: purchases or orders made by you, product and style interests, preferences, feedback, and survey responses.

•Usage Data includes information such as: how and when you use our website, how you moved around it, what you searched for, website performance statistics, traffic, location, weblogs and other communication data, loyalty programme activities and details of any other Go Group products and services used by you.

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

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website 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 notice.

Contact details including name, address, and in some cases date of birth, email, landline telephone number, mobile telephone number, hobbies & interests, insurance renewal information is obtained from trusted data partners.

Company Directors Companies House
Electoral Register Open Electoral Register
Council Tax Property Values Valuation Office
Crime Statistics Official Statistics
Corporate Statistics You Gov
General Statistics Office of National Statistics
Living Cost Survey Information National Statistics Food Survey
Property Sold Values Land Registry
Open Data from HM Government Open Data from HM Government
Anonymised Vehicle Data Anonymised Vehicle Data
Open Source Data Open Source Data

Suppression data is used by us to prevent unwanted 3rd party marketing by Post, Telephone, SMS and Email

Mailing Preference Service database which we use to mark records as not wanting to receive Postal Marketing

We use Deceased Suppression to prevent unwanted marketing to deceased loved ones and thereby causing upset. Deceased Data is obtained from National Deceased Register

Information on people that have moved is obtained from Data Partners and a National Address Change Database

The Telephone Preference Service database which we flag records as not wanting to receive any Marketing calls

We may collect personal data about you in the following ways:

•Direct interactions – you may give us your Identity, Contact, Financial, Transaction, Profile, and Marketing and Communications data (as described above) by filling in forms, entering information online or by corresponding with us by post, phone, email, telephone or otherwise. This includes personal data you provide, for example, when you:

•Create an account or purchase products on our website

•Subscribe to our newsletter, discussion boards, social media sites or create wish lists

•Enter a competition

•Join a The Cat Track Ltd loyalty programme

•Complete a voluntary market research survey

•Contact us with an enquiry or to report a problem (by phone, email, social media, or messaging service)

•Use the “refer a friend” function on our website

•When you log in to our website via social media.

•Automated technologies or interactions – as you interact with our website, we may automatically collect the following types of data (all as described above): Technical Data about your equipment, Usage Data about your browsing actions and patterns, and Contact Data where tasks carried out via our website remain uncompleted, such as incomplete orders or abandoned baskets. We collect this data by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details.

•Third parties – we may receive personal data about you from various third parties, including:

•Identity and Contact data from another individual when they purchase an e-gift card for you or use the "refer a friend" function on our website

•Technical Data from third parties, including analytics providers such as Google. Please see further information in the section entitled ‘Marketing preferences, adverts and cookies’.

•Technical Data from affiliate networks through whom you have accessed our website

•Identity and Contact Data from social media platforms when you log in to our website using such social media platforms

•Identity and Contact data from third parties, including organisations (including law enforcement agencies), associations and groups, who share data for the purposes of fraud prevention and detection and credit risk reduction and

•Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

The legal basis for processing your personal data

Consent

This is where you have consented to a specific organisation contacting you for specific reasons, using a communication channel or channels which you have agreed to. When we (The Cat Track) contact you we will be doing so for our business purposes. When we ask you for your consent for another organisation, we will do so by giving you the opportunity to tick a box online or answer a question on the phone to confirm your consent.

You can always change your mind at any time and withdraw your consent for a specific channel or even globally by following this link

•We obtain consent for our brands to contact you by telephone where your number is registered on the Telephone Preference Service (TPS) or by email and SMS.

•All cookies & similar technologies which do not meet the "strictly necessary" exemption under PECR.

Legitimate Interest:

GDPR (Recital 47) explicitly recognises the processing of personal data for direct marketing purposes as a legitimate interest.

As a direct marketing business we process personal information for various legitimate business purposes which include some or all of the following:

To enhance our services for the benefit of our customers including verification and validation
To help make the communication more relevant and contextual
To better understand how our customers interact with our services
To provide direct marketing communications which we think will be of interest to you
To determine the effectiveness of our promotional campaigns
To identify and prevent fraud
These legitimate business purposes relate to the following activities:

Direct Marketing - Postal and telephone marketing by The Cat Track Ltd and when we promote other third parties products or services, but in either case communications will be in relation to products or services which we believe are of interest to you based upon information which you have provided us.

Profiling - We will profile your information for marketing purposes to help deliver marketing communication that is more relevant to you

ID Protection & Tracing - This is in relation to appropriate agencies which could help protect your identity and prevent fraud.

We will only collect and process your personal data where we have a legal basis to do so. As a data controller, the legal basis for our collection and use of your personal data varies depending on the manner and purpose for which we collected it.

To process your personal information for the purposes of customer analysis, non-automated profiling and direct marketing, to help us with our activities and to provide you with the most relevant information as long as this does not harm any of your rights and interests.

We need your personal data to perform a contract with you. For example, to process a payment from you, fulfil your order or provide customer support connected with an order, or

For use including tracing of individuals, verification and/or validation of the identity of individuals for the purposes of, but not limited to, anti-money laundering regulations, national security, crime prevention and detection, anti-fraud processes, asset recovery and asset reunification.

To determine the effectiveness of our promotional campaigns and advertising, and to develop our products, services, systems and relationships with you.

Processing your information to protect you against fraud when using our website, and to ensure our websites and systems are secure.

Uses made of your personal data

Your personal data is used by The Cat Track to support a range of different activities. These are listed below in bold together with the types of data used and the legal bases we rely on when processing them, including where appropriate, our legitimate interests:

When creating an account and registering you as a new customer (either directly or via social media) we use your Identity and contact data to enable the performance of a contract with you.

To record your order details, process and deliver your order including: keeping you informed of the order status process your payments and any refunds, collect money owed to us and automated decision making to assist in fraud prevention and detection we use your Identity, Contact data, Financial data and transaction data to enable us to perform our contract with you, automated decision making we consider that fraud detection and prevention is in our legitimate interests to ensure that fraudulent transactors are unable to benefit from our services and in the legitimate interest of the public as whole due to the impact of fraud on the consumer market we also consider that its a necessary element of entering into a contract with you so that we are able to verify your identity and prevent fraud and for our legitimate interests for example recovery of revenue debt due to us.

To manage our relationship with you, including: providing you with any information, products and services you request from us (or that have been requested on your behalf through "refer a friend") to notify you about changes to our services, terms and conditions or privacy notice asking you to leave a review or take a survey. To enable this we will use your identity and Contact data as well as Profile Data and your Marketing and Communication Data all of which are necessary for the performance of a contract with you and necessary for our legitimate interests ie. to keep our records updated and study how customers use our products and services.

To enable you to take part in a competition, event, survey, or receive a reward for shopping with us we use your identity and Contact data as well as Profile Data, usage and your Marketing and Communication Data all of which are necessary where you have decided to enter into a competition or event, for the performance of a contract with you and are also necessary for our legitimate interests (to study how customers use our products and services, to develop them and grow our business)

To administer, protect and improve our business and our website, including: troubleshooting, data analysis, testing, system maintenance, support, data analysis, reporting and hosting of data setting default options for you, such as language and currency we will use your Identity, Contact, Profile, Technical, Transaction and Marketing and communications data to enable us to comply with our legal obligations and they are also necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, and to detect and prevent fraud).

To deliver relevant website content, online advertisements and information for you and measure the effectiveness of the advertising provided we will use your Identity, Contact, Profile, Usage, Technical, Transaction and Marketing and communications data are necessary for our legitimate interests (to study how customers use our products and services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to: improve our website, products, services, marketing, customer relationships and experiences and for market research, statistical and survey purposes we use Technical and Usage data necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To recommend products, services discounts and offers that may be of interest to you, including to send you such information by email, post or SMS. we use Identity, contact and usage data necessary for our legitimate interests (to develop our products and services and grow our business), to enable consent. Further information is available in the Marketing Preferences section.

To inform or remind you by email of any task carried out via our website which remains uncompleted, such as incomplete orders or abandoned baskets we use Identity, Contact and Usage data which is necessary for our legitimate interests (to improve the shopping experience of our customers)

To protect our customers, The Cat Track Ltd companies and website from fraud and theft we use Identity, Contact and Profile data which is necessary for our legitimate interests (to detect and prevent fraud)

Please be aware that we may process your personal data using more than one lawful basis, depending on the specific activity involved. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the list above.

We will use your information for marketing purposes as well as modelling, analysis, segmentation or suppression and any other purpose that enables us to gain understanding on how we can provide a better marketing service for you.

- to provide you with information about the products and services we offer
- to provide you with a more personalised service
- to conduct market research
- to run prize draws and promotions
- to provide you with other offers and promotions from selected third parties
- to facilitate communication between yourself and others

We use Open Source data to add additional information to our database and enable us to create profiles to create an overview of the areas in which people live and thereby enhance the marketing activity to be more relevant. This is anonymised data.

If you do not wish for your data to be used this way then please see the section - Your rights & Choices to unsubscribe or the specific company concerned.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we wish to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. We may process personal data without your consent, in compliance with the above rules, where this is required or permitted by law.

If you have any questions about how The Cat Track Ltd use any of your personal data, please contact our Data Protection Officer at or by using the details in the "How to Contact us" section

Marketing - your preferences

We may send you marketing communications and promotional offers:

•if you have opened an account with us or purchased goods from us, or registered for a promotion or event, and you have not opted out of receiving that marketing (in accordance with your preferences, as explained below)

•by email if you have signed up for email newsletters

•if you have provided us with your details when you entered a competition and you have consented to receiving such marketing (in accordance with your preferences, as explained below).

We may use your Identity, Contact, Technical, Transactional, Usage, Profile Data and Marketing and Communications Data to form a view on what we think you may like, or what may be of interest to you, and to send you details of products and offers which may be relevant for you.

We will ask you for your preferences in relation to receiving marketing communications by email, post, SMS and other communication channels.

From time to time we may also include with your order, inserts advertising goods, services or offers from other third-party companies that you may be interested in.

In respect of third party marketing communications, we may from time to time send you third party offers that you may be interested in using any of your opted in marketing channels with us however we will never share your personal data by releasing your data with any third party for marketing purposes.

You will always have full control of your marketing preferences. If you do not wish to continue receiving marketing information from us (or any third party, if applicable) at any time:

•you can unsubscribe or ‘opt-out’ by using the unsubscribe button and following the link included in the footer of any marketing email

•account holders may withdraw their consent by simply logging in to "My Account" and editing your ‘Contact Preferences’.

We will process all opt-out requests as soon as possible, but please note that due to the nature of our IT systems and servers it may take a few days for any opt-out request to be implemented.

Cookies

Our website uses cookies to distinguish you from other users of our website and to keep track of your visits. They help us to provide you with the very best experience when you browse our website and to make improvements to our website. They also help us and our advertising networks to make advertising relevant to you and your interests.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly.

For detailed information on the cookies which we and our third-party providers use and the reasons why we use them, please refer to our Cookie Policy.

Online ads

We use online advertising to keep you aware of what we’re up to and to help you find our products. Like many companies, we may target Go Group banners and ads to you when you use other websites and apps, based on your Contact, Technical, Usage and Profile Data. We do this using a variety of digital marketing networks and ad exchanges, and a range of advertising technologies such as web beacons, pixels, ad tags, cookies, and mobile identifiers, as well as specific services offered by some sites and social networks, such as Facebook’s Custom Audience Service.

Our use of analytics and targeted advertising tools

We use a range of analytics and targeted advertising tools to display relevant website content on our website and online advertisements on other websites and apps (as described above) to you, deliver relevant content to you in marketing communications (where applicable), and to measure the effectiveness of the advertising provided. For example, we use tools such as Google Analytics to analyse Google's interest-based advertising data and/or third-party audience data (such as age, marital status, life event, gender and interests) to target and improve our marketing campaigns, marketing strategies and website content. We may also use tools provided by other third parties, such as Facebook, Adroll, and Bing to perform similar tasks, using your Contact, Technical, Usage and Profile Data.

In order to opt out of targeted advertising you need to disable your ‘cookies’ in your browser settings (see Cookie Policy for details) or opt-out of the relevant third-party Ad Settings. For example, you can opt-out of the Google Display Advertising Features. As an added privacy measure, you can also use the The Digital Advertising Alliance (which includes companies such as Google and Facebook) provides a tool called WebChoices that can perform a quick scan of your computer or mobile devices, find out which participating companies have enabled customised ads for your browser, and adjust your browser preferences accordingly.

If you would like any further information about the data collected by these third parties or the way in which the data is used, please contact us.

We may disclose and share your personal data with the parties set out below:

•where you have consented for us to do so. For example, if you have consented to receive marketing materials from third parties, or in respect of third parties’ (including co-branded or jointly promoted) products and services, we may pass your data on to the relevant third parties for the purpose of sending you such marketing communications

•to business partners, suppliers, sub-contractors and other third parties that we use in connection with the running of our business for the purposes set out in the table above in the section ‘How we use your data’, such as:

othird party service providers that we engage to provide IT systems and software, and to host our website

othird party payment processing services (including Worldpay, Paypal, and in certain regions, Laybuy, (please see Terms and Conditions www.laybuy.com/uk/consumer-terms for more information) to process your payment to us.

The Cat Track does not store your payment information. Your payment details are provided to the payment processing service you have selected, who are required to comply with applicable regulations and data protection laws. Please refer to the privacy policy of the relevant provider for details of how they process your personal data

-services and to provide marketing and advertising services

-third party service providers that we engage to deliver goods you have ordered and to manage any returns

-third party service providers that we engage to send emails and postal mail on our behalf including in relation to incomplete orders or abandoned baskets, or marketing communications, to provide data cleansing services and to provide marketing and advertising services

-analytics and search engine providers that assist us in the improvement and optimisation of our website

-affiliate networks through whom you have accessed our website

•to any third party to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

•to protect our customers, The Cat Track companies and website from fraud and theft, we may share personal data that is required to make identity checks and personal data that we obtain from making identity checks (including data relating to your age, name and location), together with account information, with other The Cat Track companies and with third party organisations (including law enforcement agencies), involved in fraud prevention and detection and credit risk reduction. Please note that the other The Cat Track companies and these third parties may retain a record of the information that we provide to them for this purpose

•we may share personal data that is required to make identity checks and personal data that we obtain from making identity checks (including data relating to your age, name and location), together with account information, with organisations (including law enforcement agencies), involved in fraud prevention and detection and credit risk reduction. Please note that these third parties may retain a record of the information that we provide to them for this purpose

•if we are under a duty to disclose or share your personal data in order to comply with any legal obligation

•to our professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

Worldpay

Worldpay are the data controller in respect of the Personal Information that you give to them (and which they hold about you) when you sign up for, access, or use services, features, technologies or functions offered on the Worldpay website (including when using Worldpay to pay for goods or services offered on the Go Group websites) and in relation to Personal Information collected during the course of business as set out in their Privacy Policy which can be found on their website at www.worldpay.com/

Your data and countries outside of Europe

The personal data we collect from you may be transferred to, and stored at, destinations outside the European Economic Area ("EEA") using legally-provided mechanisms to lawfully transfer data across borders. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. We will take all steps necessary to ensure that your data is treated securely and in accordance with this privacy notice.

Whenever we transfer personal data outside the EEA, we will ensure a similar degree of protection is afforded to it by ensuring appropriate safeguards, as required by law, are in place. This may include using specific contractual clauses approved by the European Commission which give personal data the same protection as it has in Europe. More information about these is available here eur-lex.europa.eu/legal-content/en/TXT/uri=CELEX:32010D0087

Your personal information may be processed by staff operating outside of the UK who work for us or for one of our suppliers or third party partners, or service suppliers.

We will take all steps reasonably expected to ensure that when transferred your personal information is treated securely and in accordance with this privacy policy and in accordance with GDPR.

We work with Data Partners and suppliers such as Call Centres in the UK, EU, USA, Philippines and India, who call you on our behalf to conduct surveys on our behalf.

The Call Centres act as processors under strict instructions from ourselves. We monitor the calls they make to ensure quality is controlled and we inspect their premises and systems to check that security and data protection standards are of the highest quality.

We also send data to data partners who operate overseas, primarily in the United States, Philippines, India and South Africa but under strict contract rules that ensure your personal details are only processed under the same laws that we operate under here in the UK by using one of these safeguards:

Transfer data to a non-EEA country whose data protection laws have been approved by the Europeans Commission as providing adequate protection for data subjects’ rights.

Putting in place a contract with the recipient that means they must protect data to the same standards as the EEA. This is known a Model Contract Clauses.

You have a number of rights under GDPR

A. Right to be informed - When we collect your data we have to tell you what we are going to do with it primarily through this Privacy Policy and consent statement.

B. Right of access - You have the right to contact us verbally or in writing to request details of the information we hold about you. You can withdraw consent in the following ways: In writing to: Data Protection Officer, The Cat Track Ltd, 3rd Floor, Capital Tower, Greyfriars Road, Cardiff CF10 3AG By email to: or By telephone on:

C. Right of rectification - You have the right to ask us to rectify information that we hold about you if it is inaccurate or incomplete.

D. Right to erasure - This is also known as the right to be forgotten and gives you the right to request your information be removed if there is no compelling reason for its continued processing.

Please note that we keep a list of people who have asked not to be contacted which we use to ensure that you receive no further marketing from ourselves or clients as a result of our activity. Without this list your data could enter our system again from another source and we would have no record of the fact that you asked us not to contact you.

E. Right to restrict processing - This is the alternative to erasure and gives you the right to tell us to stop processing your data but allowing us to keep enough information about you to ensure that your wishes are respected in the future.

F. Right to data portability - This gives you the right to ask a holder of your information to transfer that information to another business. This right would most commonly used if you were switching banks, insurance companies, utilities companies and mobile phone providers.

G. Right to object - You have the right to object to the processing of your data for marketing purposes and profiling for marketing purposes. You also have the right to ask us to cease processing based on our legitimate interests, where there is no overriding justification for the processing of your data. Your rights and freedoms override our interests.

H. Rights related to automated decision making including profiling - We do not use automated decision making processes which would have a potentially damaging effect on you. But if we did you have the right to obtain human intervention, express your point of view, obtain an explanation of the decision and challenge it.

I. Right to withdraw consent at any time where relevant - You have the right to withdraw your consent to the processing of your information at any time and we must provide you with the information you need to do so, at the time we collect your data and each time we contact you.

J. Right to lodge a complaint with a supervisory authority - If we cannot deal with your complaint to your satisfaction you also have the right to complain to a relevant supervisory authority which include:

The Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF, or call: 0303 123 1113 or online at ico.org.uk/concerns/ and The Advertising Standards Authority www.asa.org.uk/make-a-complaint.html

You can withdraw your consent globally and also opt out from receiving marketing messages via specific method by registering this with Data Protection Officer, The Cat Track Ltd, 3rd Floor, Capital Tower, Greyfriars Road, Cardiff CF10 3AG By email to: or By telephone on:

We have also added some links to industry used suppression files that are free to record your data and this will be used by reputable marketing companies to suppress your details from their marketing activity.

Postal Marketing: you may register your opt out from receiving marketing materials by post using the following link: www.mpsonline.org.uk

Email or SMS messaging can be stopped by hitting the unsubscribe link in the emails sent to you or by replying to SMS messages with the word STOP.

Telephone calls can be prevented by registering your telephone number, mobile or landline with the Telephone Preference Service TPS using this link: www.tpsonline.org.uk

www.youronlinechoices.com is also a site that holds information as to what you can do to enhance your digital communications.