Privacy Policy V1.0

Welcome to the Buengo website or mobile application (as the case may be) (together, the ‘Platform’) operated by Buengo Ltd. We are a company incorporated in England with registration number 10780494 and our registered office is at 20-22 Wenlock Road, London N1 7GU.

We take your privacy very seriously and we ask that you read this privacy policy carefully as it contains important information on:

  • the personal information we collect about you
  • what we do with your information, and
  • who your information might be shared with.

In this privacy policy, we use the words ‘Seller’, ‘Buyer’, ‘Cause’, ‘Campaign’ and ‘Campaign Organiser’ as defined in our Terms of Service.

This policy is prepared in compliance with the requirements of the Data Protection Act 1998, as replaced and superseded by the General Data Protection Regulation (EU) 2016/679, as in force from time to time (Data Protection Law).

  • Who we are

Buengo Ltd (‘we’ or ‘us’) are a ‘data controller’ for the purposes of Data Protection Law (i.e. we are responsible for, and control the processing of, your personal information).

  • What information do we collect?
    • Personal information provided by you

We will collect personal information about you when you set up your account with us, so that you can create a profile, set up a Campaign, buy or sell items using our Platform. This information will include your name, address, email address, phone number and payment details. We will also ask you to register a username and password so you can gain secure access to your account in the future.

[Alternatively you may authorise us to collect your basic personal details from a secure online source (e.g. Google, Facebook or PayPal) to which you have already provided this information. In this case, we will access your public profile information and email address. Where we access your details via Facebook, we may, if your Facebook account settings permit it, also obtain access to your friend list. We will only use this to see if any of your friends are also using our Platform and as set out in our section (‘How will we use the information about you’).

Once you have set up your account with us, we will collect details of the Cause and/or Campaign you are supporting. Where applicable, we will ask you to provide details of how and when you are intending to fundraise and your reasons for carrying out the fundraising.

To enable us to process your donations, we will collect basic payment information from you.

We also collect personal information when you contact us, send us feedback, post material to our Platform or complete customer surveys.

  • Personal information provided by third parties

Occasionally we may receive information about you from other sources (such as credit reference agencies), which we will add to the information we already hold about you in order to help us improve our Platform and our service to you.

  • Personal information about other individuals

If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:

  • give consent on his/her behalf to the processing of his/her personal data;
  • receive on his/her behalf any data protection notices;
  • give consent to the transfer of his/her personal data abroad; and
  • give consent to the processing of his/her sensitive personal data which may include health information.
  • Sensitive personal information
    • We may ask you to provide sensitive personal information, for example when you set up a Campaign. If we request such information, we will explain why we are requesting it and how we intend to use it.
    • Sensitive personal information includes information relating to:
    • your ethnic origin
    • your political opinions
    • your religious beliefs
    • whether you belong to a trade union
    • your physical or mental health or condition
    • your sexual life, and
    • whether you have committed a criminal offence
    • We will only collect your sensitive personal information with your explicit consent.
  • Non-personal information
    • When you use our Platform, we automatically receive and store certain information which cannot be used to identify you personally, for example: the type of internet browser and mobile device you use. We use this to improve our services and statistical purposes.
    • We also conduct research on our user demographics and interests based on the information you provide us with. We may collect and analyse this information on an anonymised, aggregate basis and share it with our affiliates, agents and business partners.
    • When you use our Platform to set up a Campaign, you will be asked to provide information about your location which other users will be able to see. We may also use your location information in an aggregate way.
  • Social media

Our Platform interacts with social media websites such as Facebook (‘Social Media’) in order to make your online experience more personalised. For example, you will be able to share your activities in relation to any Campaign you have supported on Social Media websites. You can manage your privacy settings at any time by going to your profile in the app. We will ask you to log into or grant us permission via the Social Media website, which will then provide us with access to certain information that you have provided to the Social Media website. We will use, store and disclose such information in accordance with this Privacy Policy. Please remember that each Social Media website has its own policy as to how it uses, stores and discloses your information and that we take no responsibility for the actions of Social Media websites that may be enabled via our Platform.

  • Monitoring and recording communications

We may monitor and record communications with you (such as telephone conversations and emails) for the purpose of quality assurance, training, fraud prevention and compliance. We retain such information no longer than necessary, in line with our data retention policy, a copy of which is available on request.

  • Use of cookies
    • A cookie is a small text file which is placed onto your computer (or other electronic device) when you use the Platform. We use cookies and other similar tracking technologies such as web beacons, action tags, Local Shared Objects (‘Flash cookies’) and single-pixel gifs on the Platform.
    • For example, we may monitor how many times you visit the Platform, traffic data and location data. This information helps us to build a profile of our users. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually.
    • For further information on our use of cookies, including a detailed list of your information which we and others may collect through cookies please see our cookie policy.
    • For further information on cookies generally visit www.aboutcookies.org or www.allaboutcookies.org.
  • How will we use the information about you?

We collect information about you so that we can:

  • identify you and manage any accounts you hold with us;
  • process your order;
  • administer your donation;
  • personalise the look of our Platform and your page;
  • provide you with updates on Causes;
  • provide you with information of how others are using our Platform, such as your social network connections. We will only do this where we have permissions from you or where you have provided permission to the social network site as required under privacy and data protection laws;
  • provide information to Causes to let them know about contributions made to their Campaigns;
  • allow charities and not-for-profits who are registered with us to see who is fundraising for their benefit and (where appropriate) display information on their own websites about published fundraising activities and otherwise communicate with fundraisers in relation to that fundraising;
  • where the Seller provides appropriate permissions, to allow Causes to: (i) provide that Seller with more details about their activities; and/or (ii) contact individual Sellers to pass on a thank you message;
  • provide you with email updates about our Platform and your account;
  • conduct research, statistical analysis and behavioural analysis;
  • carry out customer profiling and analyse your purchasing preferences;
  • if you agree, let you know about other products or services that may be of interest to you—see ‘Marketing’ section below;
  • detect and prevent fraud;
  • do a credit check—see ‘Credit checking’ section below;
  • customise our Platform and its content to your particular preferences;
  • notify you of any changes to our Platform or to our services that may affect you;
  • carry out security vetting; and
  • improve our services.
  • Marketing
    • We would like to send you information by post, email, telephone, text message (SMS) or automated call about products and services which may be of interest to you.
    • Other organisations which may include businesses which we have selected carefully, as well as the charities we work with may also send you similar marketing messages, depending on what you agree with us.
    • We will only ask whether you would like us, other businesses and charities to send you marketing messages when you tick the relevant boxes when you set up an account with us.
    • If you have consented to such receive marketing from us, other businesses, and charities you can opt out at any time. See ‘What rights do you have?’ below for further information.
    • You can also manage your preferences by logging into your account and changing your settings in the privacy screen.
  • Anti-money laundering and credit checking
    • We may do a credit check on you:
    • so that we can make credit decisions about you;
    • to carry out bank account and identity checking; and
    • to prevent and detect fraud and money laundering
    • Our search will be recorded on the files of the credit reference agency.
    • We may also disclose information about how you conduct your account to credit reference agencies and your information may be linked to records relating to other people living at the same address with whom you are financially linked.
    • Other credit businesses may use your information to:
    • make credit decisions about you and the people with whom you are financially associated
    • trace debtors, and
    • prevent and detect fraud and money laundering
    • If you provide false or inaccurate information to us and we suspect fraud, we will record this.
  • Who your information might be shared with

We may disclose your personal data to:

  • our agents and service providers;
  • [with your consent], charities, not for profits and other Campaigns or Causes who register with the Platform.
  • our payment provider – to authorise and complete payment transactions;
  • credit reference agents—to carry out identity and bank account verification (see ‘Credit checking’ below);
  • law enforcement agencies in connection with any investigation to help prevent unlawful activity; and
  • HM Revenue & Customs, but only if we need to authorise claims for Gift Aid or other forms of tax efficient ways of giving
  • our business partners in accordance with the ‘Marketing and opting out’ section above.
  • Anonymous donations
    • We understand that you may wish to make a donation anonymously. We will not publicly display your name on your donations without your permission, however the Campaign Organiser of the Campaign you have donated to will be provided with your name (but not your email address, unless you have provided your permission for us to do so). We require all Campaign Organisers to keep this information safe and secure.
    • We do not provide any personal information relating to your donation to a Campaign Organiser unless we have your permission to do so. If you allow us to share your details with a Campaign Organiser, you may receive further correspondence from them including emails telling you more about their cause and to thank you for your donation. Any correspondence you receive from them will not be governed by this Policy; it will be governed by their privacy policies (if applicable) and you may ask them to stop communicating with you by contacting them in accordance with the terms of their privacy policy (if applicable) and the relevant laws.
  • Links to other websites

Our Platform contains links to third party websites. This privacy policy only applies to our Platform, so when you link to other websites you should read their own privacy policies.

  • Keeping your data secure
    • We will use technical and organisational measures to safeguard your personal data, for example:
    • access to your account is controlled by a password and user name that are unique to you;
    • we store your personal data on secure servers; and
    • payment details are encrypted using SSL technology (typically you will see a lock icon or green address bar (or both) in your browser when we use this technology).
    • While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet. If you have any particular concerns about your information, please contact us (see ‘How can you contact us?’ below).
  • What can I do to keep my information safe?

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

  • Transfers of your information out of the EEA

We may need to transfer your personal data to countries which are located outside the European Economic Area, for the purpose of providing our service. Any transfer of your data will be subject to a European Commission approved contract that will safeguard your privacy rights and give you remedies in the unlikely event of a security breach.

  • What rights do you have?
    • Right to request a copy of your information
      • You can request a copy of your information which we hold (this is known as a subject access request). If you would like a copy of some or it, please:
      • email, call or write to us (see ‘How can you contact us?’ below)
      • let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
      • let us know the information you want a copy of, including any account or reference numbers, if you have them
      • We may charge a fee in limited circumstances, where permitted under Data Protection Law.
    • Right to correct any mistakes in your information

You can require us to correct any mistakes in your information which we hold free of charge. If you would like to do this, please:

  • email, call or write to us (see ‘How can you contact us?’ below)
  • let us have enough information to identify you (eg account number, user name, registration details), and
  • let us know the information that is incorrect and what it should be replaced with
  • Right to ask us to stop contacting you with direct marketing

You can ask us to stop contacting you for direct marketing purposes. If you would like to do this, please:

  • email, call or write to us (see ‘How can you contact us?’ below).
  • let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
  • let us know what method of contact you are not happy with if you are unhappy with certain ways of contacting you only (for example, you may be happy for us to contact you by email but not by telephone)
  • How to contact us
    • Please contact us if you have any questions about this privacy policy or the information we hold about you.
    • If you wish to contact us, please send an email to support@buengo.com, write to us at Buengo Ltd, 20-22 Wenlock Road, London N1 7GU or call us on 0208 144 4420. You may also use the live chat function on the Platform to get in touch with us.
  • Changes to the privacy policy

We may change this privacy policy from time to time. You should check this policy occasionally to ensure you are aware of the most recent version that will apply each time you access this Platform.