Privacy policy
Policy Statement
This Privacy Policy applies to LM42 Ltd which operates the Alumni Extras website. In this Privacy Policy, “Personal Data” means any information that identifies or could identify a living individual. This Policy sets forth the standards Alumni Extras will observe in connection with Personal Data.
Data Controller
LM42 Ltd is the data controller of Personal Data processed by Alumni Extras. LM42 Ltd is a company incorporated in England & Wales, number 15060772, with its registered office at 27 Mortimer Street, London W1T 3BL, and is registered as a data controller with the UK Information Commissioner’s Office (ICO).
Your privacy
Alumni Extras (also referred to as “we”, “us” or “our”) is committed to protecting your privacy. This Privacy Policy sets out what data we collect, how we use that data and the choices we offer you, including how to access and update your information. At no time will we trade, sell or distribute your Personal Data to any individual, company, vendor or organisation in ways other than as disclosed in this Privacy Policy. If you have any questions or concerns regarding our Privacy Policy, please contact us in the way described at the end of this document.
Purposes of processing and lawful basis
We process your Personal Data where the processing is necessary for the performance of a contract with you, or in order to take steps at your request prior to entering into a contract with you, and where the processing is necessary for the purposes of the legitimate interests pursued by us, as set out in the table below.
Where we carry out processing based on legitimate interests, we have identified those legitimate interests below.
We may send marketing communications to your email address where you have consented to us doing so.
Where we process your Personal Data based on your consent, you have the right to withdraw your consent by using the Contact form of the website. Any withdrawal of consent by you shall not affect the lawfulness of processing based on your consent before it was withdrawn.
| ACTIVITY/PURPOSE | TYPE OF DATA | LAWFUL BASIS |
|---|---|---|
|
Registered user |
Personal data collected from you including name, date of birth, email and postcode |
Performance of a contract with the user, enabling the user to benefit from brand offers promoted |
|
Authenticate and manage user sessions |
Authentication data (username, password), session IDs |
Necessary for legitimate interests (grant access to platform, manage user activity, prevent fraud) |
|
Manage user relationships, including communications and customer service |
Personal data including name, email, activity, customer service tickets and browsing history |
A. Performance of a contract with the user B. Necessary to comply with a legal obligation C. Necessary for legitimate interests (facilitate user communications and inquiries) |
|
Deliver relevant content and provide recommendations based on profiling |
Preferences, reminders, site usage activity |
Necessary for legitimate interests (provide useful content and experiences to the user) |
|
Analyse usage activity to evaluate site effectiveness and optimise the user experience |
Site usage activity |
Necessary for legitimate interests (analyse the use of products/services, to keep the website updated and relevant, to develop the business and to inform marketing strategy) |
Information We Share
Information about you is an important part of our business. We do not sell your information to any third parties. All information disclosure is based on the principle of sharing only the information necessary to fulfil the legitimate business purpose. When shared, data may be transferred and hosted outside the country of origin. We only share your Personal Data with third parties as set out below:
- Information on whether and when you have joined Alumni Extras may be provided to your Higher Education Institution(s) to minimise redundant or irrelevant communications;
- We reserve the right to disclose your Personal Data to relevant authorities as required by law and when it is believed that disclosure is necessary to protect our rights and/or to comply with judicial proceedings, court order or legal process;
- Otherwise with your consent.
Accountability for onward transfer
In the event Alumni Extras discloses Personal Data covered by this Privacy Policy to a nonagent third party, it will do so consistent with any notice provided to data subjects and any choice they have exercised regarding such disclosure. If Alumni Extras has knowledge that a third party to which it has disclosed Personal Data covered by this Privacy Policy is processing such Personal Data in a way that is contrary to this Privacy Policy and/or GDPR principles, Alumni Extras will take reasonable steps to prevent or stop such processing. In such case, the third-party shall be liable for damages unless it is proven that Alumni Extras is responsible for the event giving rise to the violation.
Profiling
We use profiling in order to enhance your user experience and to present you with discounts that are relevant to you and in line with your browsing history. We do not carry out any automated decision making. If you exercise your right to object to profiling, then your Alumni Extras membership shall forthwith cease, and we will stop processing your Personal Data in accordance with our retention policy. This is because the type of profiling we carry out is fundamental to the proper operation of the Club.
How We Protect the Information
We are committed to protecting the confidentiality of your information. We take reasonable measures to secure your information, including industry standard administrative, physical and technical controls. These controls include encryption, third party audits, access controls and security testing.
International Transfers of your Personal Data
Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different from the laws of your country.
Our website servers and third party service providers operate around the world. This means that when we collect your Personal Data it may be processed in any of these countries. We have taken appropriate safeguards to protect your personal information, such as ensuring the third party is on the ‘Privacy Shield’ list, or working with third parties in countries we deem to have adequate data protection laws. If we share personal information with a third party acting as our data processor, we remain responsible for how that information is processed.
Cookies and web beacons
We do not use cookies on the website but some third parties (such as brand partners and tracking utilities) use cookies and web beacons on their site(s). We do not have access or control over these tracking technologies. We do not share your personally identifiable data with these third parties.
This Privacy Policy covers Alumni Extras’ use of cookies and the white label subdomains delivered by us, only. This Privacy Policy notice does not cover the use of cookies by any third parties.
Opting Out
All Alumni Extras marketing emails contain an unsubscribe link to stop future routine correspondence (but not necessary operational emails).
If you would like your personal information, including email address, to be completely removed from our databases, you should use the Contact form. We will respond to your request within thirty (30) business days. Completely removing your personal information from our databases will negate your ability to login and access Alumni Extras benefits.
Notification of Changes to the Privacy Policy
This Privacy Policy may be reviewed and amended from time to time. You will be notified of changes to this Privacy Policy by a notice posted on the login page. The notice will contain a link whereby the amended privacy policy can be examined in full. In this way you will be made aware of policy changes prior to browsing or shopping. We may email periodic reminders of our notices and conditions, but you should check our website frequently to see recent changes. As always, if you are not amenable to the conditions of a revised Privacy Policy you may opt out from us contacting you by the means outlined in the ‘Opting Out’ section above.
Retention Period
We will store your Personal Data while you remain registered as a user of Alumni Extras. If you request removal we will close your account. We will retain your Personal Data even after we have closed your account to the extent necessary to comply with our legal obligations and to resolve disputes, and to fulfil your request not to receive further communications from us.
Merchant’s privacy policies
Many Alumni Extras offers will redirect you to a participating brand’s website. At this point you will be on the brand’s website and the brand’s privacy policy will then apply to any information you provide.
Complaints and dispute resolution process
If you have questions or concerns regarding this Privacy Policy, please submit your enquiry through the Contact form.
Alumni Extras will endeavour to respond to any such inquiries or complaints within 72 hours. You have the right to lodge a complaint with the data protection supervisory authority in the UK, the ICO. The ICO website is at https://ico.org.uk/. However, we would request that you contact our Data Protection Officer before making a formal complaint.
Alumni Extras commits to periodically reviewing and verifying the accuracy of this Privacy Policy and applicable data privacy legislation, and remedying issues identified.
Contact Us
To get in touch, please complete the Contact form on the website.