Privacy Policy

At club drinki we respect your personal privacy. In order to give you the best experience we can when you seek to take advantage of all membership benefits and promotions we facilitate, we need to utilise certain data from you without which we cannot facilitate the promotions which might match your location and preferences.

The purpose of this document is to provide more detail on our policies with respect to the collection, use, and disclosure of information we collect and receive from members of club drinki.

Information We Collect

Non-Attributable Information

When you become a member of club drinki our technical team may (i) automatically record information that your mobile phone/device sends or transmits, including your device type, any device ID number, relevant settings,your geographical location (which you consent to when becoming a member of club drinki so as to have access to promotions) and information about your use of the membership benefits we provide such as bars visited, information you entered, (ii) record which search terms you used, or which referring/exit pages brought you to our page, and date/time information, (iii) record information provided by you, such as your gender or date of birth, (iv) use information about or from another content delivery platform, and (v) record information from such other sources such as viewings on our website or on our social media presence, or information provided by Affiliated Partners (meaning third parties either we or you have approved) (collectively, “Non-Attributable Information”).

Personal Information

We may ask members of club drinki to provide us with somepersonal information—information that can be used to identify or contact you,and information on your use of all membership benefits (“PersonalInformation”). Examples of the Personal Information we may collect include your name, date of birth, gender, mobile phone number, email address and place of residence as well as any other personal information you have consented to us collecting whether directly or indirectly through for example an Affiliated Partner.

Other methods may be utilised to collect your Personal Information, for example when visiting the premises of any vendor top articipate in a member promotion when you are physically visiting the place of business of one of our Affiliated Partners, such as by using scanning and check-in and presence location data gleaned from your mobile device. If you do not wish to have your Personal Information collected by these methods, you may not be able to participate in any club drinki facilitated promotion.

We may also receive Personal Information from Affiliated Partners provided by you in the course of your using our membership services,or from third parties subject to the limitations of the Privacy Policies of those Affiliated Partners or third parties.

Information About Use of Membership Services and Promotions

So as to enable members of club drinki to participate in promotions that we facilitate from certain Affiliated Partners, such as when you visit a bar to redeem a free drink offer, we may receive information about transactions that you make at an Affiliated Partner including the Affiliated Partner name, the location, the date and time, the transaction amount, the purchased items and other personal information about you (“Transaction Data”),from payment processing vendors, from banks or from credit or debit card networks or issuers (“Transaction Providers”).

Unless the privacy policy of the Affiliated Partner that you accepted already allows for this information sharing, we will ask for your permission (by your explicit opt-in, like when you register your payment Card) in order to receive this information. In casewe need to share Personal Information with Transaction Providers to identifyyou to be able to receive the Transaction Data that determines whether offersor rewards apply to you, then we will ask for your permission (“opt-in”).

Use of Information

References to “using” and “processing” information in this document include using cookies or other storage means on a computer or mobile device, statistical or other analysis of the data and storing, collecting, deleting, combining, disclosing and transferring information within our organisation.

Personal Information

We commit to use Personal Information only as follows: (i) to facilitate the bringing of promotions to members of club drinki, (ii) to seek to improve your experience of club drinki, (iii) to provide you with software updates and/or promotions as may be the case, (iv) to seek member feedback on promotions and member general interests, and (v) to bring to your attention promotions and offers that we can facilitate and which we consider you will find useful or interesting.

We may match data from your transactions with Affiliated Partners and/or the content information with our usage data in a personally identifiable form in order to perform accounting reconciliation and/or provide targeted promotions to you; but to protect your privacy, our Affiliated Partners and drinki will perform this matching in a protected environment that does not allow our Affiliated Partners to gain Personal Information you have not opted in to disclose to them, unless you choose to identify yourself at the Affiliated Partner’s place of business as a club drinki member to use an offeror redeem a reward. By enabling an Affiliate Partner to identify you as a club drinki member, you are allowing them to identify and store that transaction as a drinki-related transaction.

Non-Attributable Information

We may use Non-Attributable Information for certain purposes, for example, trend analysis through aggregated demographic information about our members generally, and thus, to improve the functionality of our membership services and to facilitate more relevant promotions to members.We may also share this Non-Attributable Information with our Affiliated Partners to allow them to assist us in facilitating promotions and other membership driven incentives to you. Any information shared with Affiliated Partners in this context will not contain nor be linked to your Personal Information unless you have given us your explicit consent through an “opt-in” mechanism on the Application.

Affiliated Partners

We may request your permission to allow us to share yourPersonal Information with Affiliated Partners. If you so consent, we may share Personal Information with one or moreAffiliated Partners (as to data regarding your participation in memberpromotions, though, only the usage data that relates to a particular AffiliatedPartner will be shared with that Affiliated Partner). In all other cases, wewill only share data with Affiliated Partners in an aggregated (i.e., notpersonally identifiable) form for analysis. If we share Personal Informationwith an Affiliated Partner, we will require in our agreement with thatAffiliated Partner that this information not be shared outside the AffiliatedPartner but we cannot be held liable for the failure of any Affiliated Partnersto comply with such agreement.

Cookies & Tags

We may use “cookies” (a data file in your device’s memory),and/or other storage on your device to help us collect, maintain, and use informationas follows: (i) to improve our communications with you as a club drinki memberfor example by saving information relating to your member account and/oractivity for future promotions; and (ii) to improve our understanding of whichmembership benefits you enjoy and use. Please note you may direct your browser to stop accepting cookies from anywebsite you visit, although if you do not accept relevant cookies you may notbe able to participate in all club drinki facilitated promotions.

We may also use data collection tags in combination withcookies to analyse member’s usage patterns anonymously and to facilitateadvertisements to you. Usage trackingallows us to count members who have visited certain web sites and pages withinweb sites, or used applications or features, to analyse the behaviour of membersof our web sites and application, in order to improve the web sites andapplication, and to assess the effectiveness of promotional campaigns.

Information We Share

Our objective is to only share Personal Information to theextent required to allow you to participate in any member promotion that clubdrinki is seeking to facilitate. Otherwise we shall only share Personal Information with you or under thefollowing circumstances:

Non-Attributable Information. As noted above, we may sharewith third parties information in a form that does not disclose your PersonalInformation (for example on an aggregated basis), nor allow you to bepersonally identified, for business related analysis, demographic profiling andsimilar purposes. We may share suchinformation so that our partners better understand how interested our membersare in their promotions and improve their offerings and so that additionalpartners can see the benefits of directing promotions to members of club drinkiand may also become our Affiliated Partners and further improve the promotionsand offers for our members.

Personal Information. In order to take advantage of a promotion being offered by an Affiliated Partner to members of club drinki, you may be required to provide the Affiliated Partner with identifying information(which may include Personal Information) at the place of business of the Affiliated Partner, to enable the Affiliated Partner to verify that you are a club drinki member. The Personal Information you provide to the Affiliated Partner in this context will only be used by the Affiliated Partner to record the transaction you make at the time you are participating in a club drinki facilitated promotion, and the Affiliated Partner will then share the transaction information with us. Any Personal Information used in this context will be bound by this Privacy Policy. If you do not wish to share Personal Information with an Affiliated Partner you can choose not to provide such information which may result in you being unable to participate in a club drinki facilitated promotion with such Affiliated Partner.

Our Suppliers. We may engage with third party companies andindividuals to facilitate the provision of member related services (e.g.,without limitation, maintenance services, database management, web analytics)or to assist us in analysing how our membership benefits are used. These thirdparties may have access to your Personal Information but only to perform thesetasks on our behalf and may not disclose or use it for any other purpose.

Compliance with Law. In certain circumstances we may have an overriding legal obligation tocooperate with a regulator or other official legal body requiring thedisclosure of Personal Information, in which case we will disclose such informationso as to meet our legal obligations and to fully cooperate with any such body.

Updating and Deleting Personal Information

You may review, update, correct or delete your Personal Information in your registration profile by contacting us or by making the appropriate modifications in your membership account. If you completely delete all such information, then your account may become deactivated.

Security

We employ appropriate measures designed to safeguard andprotect your information from unauthorised access and disclosure. In addition,we will delete information after it is no longer useful in the provision ofmember related services.

International Transfer

Your information may be transferred to and maintained on computers located outside of your country of residence. This Privacy Policy and its protection for you still applies in other jurisdictions and your submission of such information represents your agreement to that transfer.

Links to Other Sites

This Privacy Policy only applies to our sites and applications, we are not responsible for the privacy practices or the content of other websites even if directed to such sites through banners or advertising on our website. The fact that we maylink to or incorporate a partner's services, functionality, or website, orpresent a banner ad or other type of advertisement, is not an endorsement orrepresentation of our affiliation with that third party, nor is it anendorsement of their privacy or information security policies or practices.

Children

Membership of club drinki is naturally not open to ordirected at children. If we becomeaware that a person under the age of 18 has provided false information orsomehow managed to register as a member of club drinki we shall immediatelydelete such information from our files.

Agreement

In signing up to become a member of club drinki you agree to terms of this Privacy Policy and to any updates thereto. Any changes will be effective immediately as of the date the modified Privacy Policy is posted on our website.

Contact

Our aim is to facilitate the best promotions we can to members of club drinki. If you need to contact us please write to us at our registered office:

DRINKI LIMITED,
UNIT A3 BROOMSLEIGH BUSINESS PARK, WORSLEY BRIDGE ROAD
SE26 5BN LONDON, UNITED KINGDOM