Privacy Policy
PLEASE READ THIS PRIVACY POLICY CAREFULLY.
Like many internet companies, we collect some personal information (Personal Data) about you when you use our Products.
Please read this Privacy Policy carefully, as it tells you what Personal Data we collect from you and how we use it. It applies to your use of our Products (including visiting our Website) and any Personal Data we get from you when you contact us or we contact you.
This Privacy Policy forms part of our Customer Terms so if you need to find a definition of a word or phrase that we use here, please see the Customer Terms.
Privacy Policy
Last modified 29 December, 2022
1. PERSONAL DATA WE USE
Here we explain the different types of Personal Data that we collect from you and how we use it.
1.1 User Account data. When you create a User Account, you will give us your name and email address and/or mobile phone number. We use this information to enable you to login and manage your account. Plus we will send you email and SMS notifications about the Products, Results and your account. We use SendGrid as our email service.
1.2 Payment data. When you purchase a Product from us, you will input your Payment Card information and your name and address. We use a third party payment processor, Stripe, to process payments which means that we do not see or store your Payment Card information. All we can see on Stripe is your contact information and the last 4 digits of your Payment Card number.
1.3 Social media and advertising data. We run organic posts and advertising campaigns on Instagram, Facebook, TikTok, YouTube, Pinterest and Reddit, so we may have access to your social media handle if you engage with us on those platforms. We use the social media platform pixels which mean we can track which social media platforms and which advertising campaigns our customers have clicked on to find us. We don’t collect additional information about you from your social media profile, but the social media platforms may do, so you should check their privacy policies.
1.3 Analytics data. We use Google Analytics, Google Optimize, Hotjar to help us understand how people use our Products (which Website pages you visit, how long you spend browsing, which Products you purchase). It also tells us which country you are visiting from, the type of internet browser and device you use.
1.4 Contact information. If you contact us by email or via customer support, you will be giving us your email address, plus whatever additional personal information (such as your name) that you choose to provide. We will keep a copy of our email exchanges with you.
2. LEGAL BASIS FOR OUR USE OF YOUR PERSONAL DATA
To comply with Data Protection Laws, we only use your Personal Data if we have a legal basis for doing so. Where we use your Personal Data, it will be based on one of the following:
2.1 Consent. For some of the ways we use your Personal Data, we will get your consent. For example, where we use cookies, we have a cookie banner where you can decide if you accept cookies. For ongoing marketing by email or SMS, we will get your consent in advance and you can withdraw your consent at any time.
2.2 Contract. We will use your Personal Data in order to complete a contract with you (for example the contract between us when you purchase a Product) and to manage your User Account. This includes processing your payment data and sending you invoices and receipts.
2.3 Legitimate interests. We use your Personal Data where we have a legitimate interest to do so (which is a legitimate business reason that does not override your rights), to measure analytics on our Website, to respond to any customer queries, to promote our Products, or for general management and development of our Products.
2.4 Legal obligations. In some situations, we may have to use your Personal Data to comply with our legal or regulatory obligations.
3. WHO WE SHARE PERSONAL DATA WITH
3.1 Never Sell Your Data. Firstly, we never sell your Personal Data. We only share it with third parties where we use their products or services as part of our business, to help deliver the Products.
3.2 Third Parties. Here is a list of the third parties that have access to your Personal Data. We have a contract with each of them that puts them under a legal obligation to protect your data.
| Name | What they do for us | Their privacy policy | Location |
|---|---|---|---|
| Amazon Web Services | Website hosting | https://aws.amazon.com/privacy/ | US |
| Website analytics and optimisation | https://policies.google.com/privacy | US | |
| Hotjar | Website analytics | https://www.hotjar.com/legal/policies/privacy/ | US |
| Meta (Facebook, Instagram) | Social media (including advertising) | https://privacycenter.instagram.com/ | US |
| Social media (including advertising) | https://policy.pinterest.com/en-gb/privacy-policy | US | |
| Social media (including advertising) | https://www.reddit.com/policies/privacy-policy | US | |
| SendGrid (part of Twilio) | Email provider | https://www.twilio.com/legal/privacy | US |
| Stripe | Payment processing | https://stripe.com/en-gb/privacy | US |
| TikTok | Social media (including advertising) | https://www.tiktok.com/legal/page/eea/privacy-policy/en | US |
| YouTube | Social media (including advertising) | https://policies.google.com/privacy | US |
3.3 Transferring your information overseas. We are a global business and Personal Data may be stored and processed in any country where we do business. Most of our third party partners are based in the United States. If you are a customer in the UK, EU, or Switzerland we have data processing agreements in place with our third party partners that include the standard contractual clauses or another legal method that ensures adequate protection, to comply with the laws on data transfers.
4. YOUR RIGHTS AND CHOICES
You have rights when it comes to your Personal Data.
4.1 Access it. You have the right to access the Personal Data we hold about you (which you can either do by logging into your User Account, or contacting us and asking what data we hold about you).
4.2 Fix it. If you see that there is an error in the information that we hold about you, you can ask us to rectify it if it is inaccurate, incomplete or outdated.
4.3 Erase it. In certain situations, you can ask us to erase your Personal Data.
4.4 Restrict it. In certain situations, you can ask us to restrict the use of your Personal Data.
4.5. Export it. Where technically feasible, you can ask to export your Personal Data so you can use it with a third party (data portability).
4.6 Object to it. Where we process your data based on our legitimate interests, you can object to us processing your Personal Data, and where we process your data based on consent, you can withdraw your consent and unsubscribe at any time.
5. HOW TO EXERCISE YOUR RIGHTS
To exercise any of your rights, just get in touch with us at hello@makeme.club and tell us what you would like to do. We will let you know if we need additional information from you to respond to your request.
6. COOKIES POLICY
6.1 Intro. Like most modern websites, we use cookies to make your experience on our site better, faster and more convenient. We use both persistent cookies (which stay on your browser for a long period of time, or until you delete them), and session cookies (which are automatically deleted when you close your browser). To understand how we use cookies and how you can remove cookies from your browser, please see below.
6.2 What are cookies? A cookie is a small data file sent by us to your computer/device and from your computer/device to us when you use our Products.
6.3 Types of cookies. These are the cookies we use. We will update this list from time to time.
| Cookie | From | Description | Duration | Type |
|---|---|---|---|---|
| _fbp | Meta | Meta (Facebook) set this cookie to display advertisements when either on Facebook or on a digital platform powered by Facebook advertising, after visiting the website. | 3 months | Advertising |
| _ga | Google analytics set this cookie to calculate visitor, session and campaign data and also keeps track of site usage for the site'sanalytics report. The cookie stores information anonymously and assigns a randomly generated number to recognize unique visitors. | 2 years | Analytics | |
| _pin_unauth | This cookie is placed by Pinterest Tag when the user cannot be matched. It contains a unique UUID to group actions across pages. | 1 year | Advertising | |
| _tt_enable_cookie | TikTok | Tiktok set this cookie to collect data about behaviour and activities on the website and to measure the effectiveness of the advertising. | 1 year 24 days | Advertising |
| _ttp | TikTok | TikTok set this cookie to track and improve the performance of advertising campaigns, as well as to personalise the user experience. | 1 year 24 days | Advertising |
6.4 How to turn off cookies. Our cookie banner will ask you if you want to accept cookies. So you have the option to decline cookies then. If you accept cookies but then change your mind, you can remove the cookies on your browser. These websites tell you how to remove cookies: www.allaboutcookies.org or www.youronlinechoices.eu.
7. KEEPING YOUR PERSONAL DATA SECURE
7.1 Security Measures. We make reasonable efforts to provide a level of security appropriate to the risk associated with the processing of your Personal Data. We maintain organisational, technical and administrative measures designed to protect Personal Data covered by this Policy against unauthorized access, destruction, loss, alteration or misuse. Personal Data is only accessed by a limited number of personnel who need access to the information to perform their duties.
7.2 No guarantee. Please be aware that sending information via the internet is never 100% secure, so we cannot guarantee the security of any Personal Data that you send to us via our Website or App or by email.
7.3 Retention. We only keep hold of your Personal Data for as long as we need it to provide the Products to you, or as we are required to keep it to comply with Applicable Laws.
8. CHANGES TO THIS PRIVACY POLICY
8.1 Updates. We will update this Privacy Policy from time to time, so please check back here regularly. Any changes to the Privacy Policy will take effect when they are published on our Website.
8.2 Notifications. If we have your email address, we will notify you by email of any substantial changes to our Privacy Policy.
9. CONTACT US
If you have any questions about this Privacy Policy, please get in touch at hello@makeme.club.
This Privacy Policy is issued by Make Me Club, a trading name of Winnow Consulting Ltd, registered in England and Wales with company number 09425302 and registered office address at 36 Mansfield Road, London NW3 2HP.