At Boxaroo, your privacy is critically important to us.

Boxaroo respects your privacy and is committed to protecting your personal data. It is our policy to respect your privacy regarding any information we may collect while operating our websites and our services.

 This privacy notice will inform you as to how we look after your personal data when you visit our website or use our services (regardless of where you do it from) and tell you about your privacy rights and how you are protected. We respect your privacy and are committed to protecting any personally identifiable information you may provide us.

CONTROLLER OR PROCESSOR

 We are Boxaroo ("we", "us" and "our") and we are registered in Singapore with the UEN number 202022209E. Our European subsidiary is registered in Spain with the NIF number B72561186. Our parent company and our subsidiaries operate within the bounds of data privacy laws in Singapore, the EU and all the countries we offer our services in. We are either the controller responsible for your personal data or the processor for the purposes specific to providing our services to our customers  (collectively referred to as “we”, “us” or “our” in this privacy notice).

 

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how Boxaroo collects and processes your personal data through your use of this website (which includes the domain www.boxaroo.co and all related subdomains), including any data you may provide through this website when you interact with us, sign up to our newsletter, purchase a product or service or take part in a competition and the Boxaroo platform (including all subdomains under the domain www.boxaroo.co), subject to the relevant terms and conditions and data processing agreements agreed to with Boxaroo.

This website is not intended for children and we do not knowingly collect data relating to children. By using the website, you confirm that you meet this requirement. If we discover that we have inadvertently collected personal data from a child, we will promptly take all reasonable measures to delete that personal data from our systems.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications, including social media platforms such as Linkedin and YouTube and so on. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.\

 

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Through our websites and services, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data includes first name, last name, username or similar identifier, social media handle, job title and company
• Contact Data includes billing address, delivery address, email address and telephone numbers
• Transaction Data includes details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes downloads, purchases or requests made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Specifically, for users of the Boxaroo Platform, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier, social media handle, job title and company.
• Contact Data includes billing address, email address and telephone numbers.
• Transaction Data includes details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes downloads, purchases or requests made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes 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 in law 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.

 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 offenses.

We do not and will not sell any personal data to third parties.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• apply for or use our products or services;
• subscribe to our service or publications;
• request marketing or content to be sent to you;
• attend one of our events or meet us at an event hosted by a third party
• correspond with our Sales or Customer Success teams
• enter a competition, promotion or survey; or
  give us some feedback.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. Please see our cookie policy for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
• Technical Data from analytics providers such as Google and Hubspot based outside the EU, Singapore and other markets we operate from;
• Identity and Contact Data from data brokers or aggregators such as Datafox, Zoominfo, Lead IQ and Dun & Bradsheet based inside and outside the EU, Singapore and other markets we operate from.
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU, Singapore and other markets we operate from.

4. HOW WE USE YOUR PERSONAL DATA

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

• Where we need to perform the contract we are about to enter into or have entered into 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.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

PROTECTION OF CERTAIN PERSONALLY-IDENTIFYING INFORMATION

Boxaroo discloses potentially personally-identifying and personally-identifying information only to those of its employees, contractors and affiliated organizations that (i) need to know that information in order to process it on Boxaroo's behalf or to provide services available at Boxaroo's website, and (ii) that have agreed not to disclose it to others. Some of those employees, contractors and affiliated organizations may be located outside of your home country; by using Boxaroo's website, you consent to the transfer of such information to them. Boxaroo will not rent or sell potentially personally-identifying and personally-identifying information to anyone. Other than to its employees, contractors and affiliated organizations, as described above, Boxaroo discloses potentially personally-identifying and personally-identifying information only in response to a subpoena, court order or other governmental request, or when Boxaroo believes in good faith that disclosure is reasonably necessary to protect the property or rights of Boxaroo, third parties or the public at large. 

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. 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 table below:

 

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	(a) Identity (b) Contact	(a) Performance of a contract with you
To process and deliver our services including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	(a) Necessary for our legitimate interests (to study how customers use our products/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	(a) Technical (b) Usage	(a) 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 make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	(a) Necessary for our legitimate interests (to develop our products/services and grow our business)
In the event that we sell or buy any business or assets, disclose your data to a prospective seller or buyer, or in the event we are the subject of acquisition by a third party.	(a) Transaction Data	(a) Necessary to comply with a legal obligation (b) Necessary for our legitimate interests (to carry out such transactions).
To comply with any rights requests you make.	(a) Identity (b) Contact (c) Transaction	(a) Necessary to comply with a legal obligation
To send you a gift on behalf of a Customer of ours (Controller) with Boxaroo as a Processor.	(a) Identity (b) Contact	(a) Necessary for our legitimate interests (for the running of our business and delivery of our services), or (b) On the basis of consent
To send you a gift.	(a) Identity (b) Contact	(a) Necessary for our legitimate interests (for the running of our business and delivery of our services), or (b) On the basis of consent

 

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, 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 for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us, purchased goods or services from us, if you provided us with your details when you entered a competition, registered for a promotion or otherwise submitted your information in a form provided by us and, in each case, you have not opted out of receiving marketing communications.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any company outside the Boxaroo group of companies for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by contacting us here hello@boxaroo.co.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

COOKIES

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 this website may become inaccessible or not function properly. 

CHANGE OF PURPOSE

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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need 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.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above: 

• Any member of our group, which means our subsidiaries, affiliates or a parent company from time to time, who support our processing of personal data under this notice.
• Customers of ours who are sending gifts to you.
• Companies that we work with or partner with to deliver our content, services or events to you, such as ticketing companies, payment service providers, events companies, delivery companies and catering companies.
• Professional services and technology providers such as marketing agencies, advertising partners, website and landing page hosts, IT support services, and marketing and sales technology companies, such as CRM or Marketing Automation tools, who help us run our business.
• Analytics and search engine providers that assist us in the improvement and optimisation of our Services (this will not identify you as an individual). See our Cookies Policy for more information.
• Third parties 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.
• Credit reference agencies, law enforcement and fraud prevention agencies, so we can help tackle fraud.
• Companies approved by you, such as social media sites (if you choose to link your accounts to us). 

We may retain or provide third parties with aggregated but anonymized information and analytics about our customers and recipients but, before we do so, we will make sure that it does not identify you. 

We require all third parties 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.

6. INTERNATIONAL TRANSFERS FROM EEA

We share your personal data within Boxaroo. This will involve transferring your data outside the European Economic Area (EEA).

 Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, 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 by the European Commission or equivalent authority in the UK.
• We may use specific contracts approved by the European Commission and Information Commissioner's Office which give personal data the same protection it has in the UK and EEA.

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

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the website, you are responsible for keeping this password confidential.

We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, including using SSL encryption to secure our website and protect your information in transit. We cannot guarantee the security of your data transmitted to the website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

8. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

In our capacity as a processor of our customers, we will only retain your personal data for the duration of the term of the agreement that we have with the relevant customer.

In our capacity as a controller, we will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements, and in some cases for six years after that to identify any issues and resolve any legal proceedings.

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 unauthorized 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 request erasure below for further information.

In some circumstances we may anonymize 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.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are outlined in the Glossary below. If you wish to exercise any of the rights set out in the Glossary, please contact us here hello@boxaroo.co.

 If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority, if you are in the EU, please see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

LAWFUL BASIS

We try to respond to all legitimate requests within 30 business days. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. GLOSSARY

LAWFUL BASIS

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.

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

YOUR LEGAL RIGHTS

You have the right to:

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 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. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

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 on 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.

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 the 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 use or where we used the 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.

 

CONTACT US

If you have any questions about this Privacy Policy, please contact us via hello@boxaroo.co.