Effective Date: 1st August 2021
We may collect, use, store and transfer different kinds of personal data about you or your listed dependants on SES as follows:
Identity Data: may include first name, last name, username or similar identifier, title, date of birth, photograph or profile image. In certain circumstances we may also collect and store an ID Document and utility bill.
Contact Data: may include residential address, email address and mobile telephone number. If at any point in the future you change your details, you must tell us promptly about those changes.
Device Data: includes the type of mobile device you use, a unique device identifier such as the mobile phone number used by the Device, mobile network information, your mobile operating system, the type of mobile browser you use, and IP Address.
Content Data: includes information stored on your Device, including login information or other digital content.
Profile Data: includes your username and password, in-app communications, preferences, feedback and survey responses, bonus history, details of your use of any of our services or your visits to any of our website(s) and any other information we learn about you through our relationship with you and the way you operate our services.
Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Location Data: includes your geo-location data that determines your current location.
Other than a picture of you (which is considered biometric data and within the meaning of Special Categories of Personal Data), which we may get access to if you register with us via a social network, or if we need to ask you for a selfie photograph together with an ID Document in order to be able to provide you with certain services, we do not collect any other 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).
In certain circumstances, when you apply for a service (and throughout your relationship with us) we may need to collect a ‘selfie’ video or photograph and an ID Document from you. We would do this in order to verify who you are as part of our legal obligations to carry out certain Anti-Money Laundering and Counter-Terrorism Financing checks and for our own fraud detection purposes. You do not need to provide us with this information, but if you don’t, we may not be able to offer some or all our services.
We will collect and process the following data about you:
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:
We will only send you marketing communications, e.g., by email, push notifications or text, where we have a lawful basis for doing so. We may use your Identity, Contact, Transactional, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant to you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or if you have registered with us and have not opted out of receiving marketing.
You can ask us to stop sending you marketing messages at any time following the opt-out links on a marketing message sent to you or by contacting us at any time. You can stop receiving push notifications by adjusting SES’s push notification settings on your phone.
We will not share your personal data with any third party for marketing purposes without first getting your explicit express opt-in consent.
Purpose/activity: To install SES and register you as a new SES user
Type of data: Identity, Contact, Device
Lawful basis for processing: Performance of a contract with you
Purpose/activity: To provide and administer the services throughout your relationship with us, including linking your account to a payment card, executing your instructions; processing transactions, resolving any queries or discrepancies and administering any changes.
Type of data: Identity, Contact, Financial, Transaction, Device
Lawful basis for processing: Performance of a contract with you, necessary for our legitimate interests (e.g. to administer our service), to comply with a legal or regulatory obligation
Purpose/activity: To manage risk and crime prevention including (i) detecting, investigating, reporting and preventing crime, (ii) obeying laws and regulations which apply to us, (iii) responding to complaints and resolving them and (iv) to help us make decisions on your account.
Type of data: Identity, Contact, Financial, Transaction, Profile
Lawful basis for processing: Performance of a contract with you, to comply with our legal obligations, necessary for our legitimate interests (e.g., to develop and improve how we deal with financial crime)
Purpose/activity: To manage our relationship with you and ongoing customer services, including notifying you of changes to SES or any services, and contacting you with information relevant to the operation and maintenance of your account
Type of Data: Identity, Contact, Transaction, Device, Content, Financial, Profile, Usage, Marketing and Communications
Lawful basis for processing: Performance of a contract with you, necessary for our legitimate interests (e.g., to keep records updated, running and administration of our business), necessary to comply with legal obligations (e.g., to inform you of any changes to our terms and conditions
Purpose/activity: To enable you to participate in a prize draw, bonus, competition or complete a survey
Types of Data: Identity, Contact, Device, Profile, Marketing and Communications, Usage
Lawful basis for processing: Performance of a contract with you, necessary for our legitimate interests (e.g. to analyse how customers use our products/services and to develop them and to grow our business)
Purpose/activity: To administer and protect our business and SES including troubleshooting, data analysis and system testing
Types of data: Identity, Contact, Device, Content, Profile, Usage, Location
Lawful basis for processing: Performance of a contract with you, necessary for our legitimate interests (e.g., for running our business, provision of administration and IT services, network security), to make recommendations to you about goods or services which may interest you, to measure and analyse the effectiveness of the content that we serve you, to monitor trends so we can improve SES
Lawful basis for processing: necessary for our legitimate interests (e.g., to develop our products/services and grow our business), consent
We may monitor or record calls, emails, text messages or other communications in accordance with applicable laws for the purposes outlined in the above section.
We may share your personal data with our third party service providers, agents, subcontractors, subprocessors and other associated organisations and group companies of Sheology for the purposes outlined in the ‘Purposes for which we will use your personal data’ section above. Entities to which we pass your personal information may also include:
When using third party service providers, they are required to respect the security of your personal data and to treat it in accordance with the law.
Some of our third party service providers are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
When we transfer your personal data out of the EEA, at least one of the following safeguards will be implemented:
We take measures, including administrative, technical and physical safeguards, to try to protect your personal data from loss, theft, misuse and unauthorised access, disclosure, alteration and destruction.
We will retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.
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, regulatory, tax, accounting or other requirements.
We have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for at least 5 years after they cease being customers for legal and regulatory purposes. However we will usually keep personal data for at least 6 years after the end of your contractual relationship with us in accordance with appropriate limitation periods.
In some circumstances you can ask us to delete your data: see ‘Your legal rights’ section 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.
Under certain circumstances you have the following rights under data protection laws in relation to your personal data. You can exercise any of these rights at any time by contacting us.
Request access to your personal data (commonly known as a ‘data subject access request’). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where we no longer need to process your information for the purposes for which it was provided and there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Please note that we will only comply with such erasure requests only to the extent it is legally obligated to, and depending on your account activity until that date, certain personal data may be maintained in accordance with anti-money laundering and counter-terrorist financing legislation or other obligations to which we reasonably believe we are subject. Please note that if you request us to delete your information, we may have to suspend the operation of your account and/or the products and services we provide to you.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. Please note that if you object to us processing your information, we may have to suspend the operation of your account and/or the products and services we provide to you.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data 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 process or where you provided us with this information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
For further information on cookies generally visit www.aboutcookies.orgorwww.allaboutcookies.org.
There are two types of cookies:
The cookies placed on your device fall into the following categories:
We may use the following 3rd party software frameworks that may store data on the device in our iOS and Android apps:
The primary purpose:
This allows SES to create deep links that work when downloading the application from the App Store first.
This enables us to monitor our audience size and usage pattern and send SESp notifications.
This enables us to monitor our audience size and usage pattern.
This enables us to monitor our audience size and usage pattern.
This enables us to allow users to register and login to SES with their Facebook account and perform analytics and marketing campaigns on Facebook
Used for Google services e.g. Google Maps
This enables us to monitor our audience size and usage pattern
Used to provide email services to our users and keep track of usage