Privacy policy

Moonpig Group plc Corporate Privacy Notice

Introduction

Welcome to Moonpig Group plc’s privacy policy

Moonpig Group plc respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our Corporate website (regardless of where you visit it from) and tells you about your privacy rights.

Important information and who we are

Moonpig Group plc (collectively referred to as “Moonpig Group”, “Moonpig” "we", "us" or "our" in this privacy policy) is a data controller and is responsible for your personal data. We are part of a group of companies in the United Kingdom and the Netherlands (the Moonpig Group) and also operate in Ireland, Australia and the US.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

Each of the Group’s brands has its own privacy notice setting out Information about how we process customer data. These can be found on each brand’s websites and apps:

Our websites and services are not meant to be accessed by children and we do not knowingly collect data relating to children.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us.

The privacy policy is separated into specific areas and is set out below.

  1. The data we collect about you
  2. How is your personal data collected?
  3. How we use your personal data
  4. Disclosures of your personal data
  5. Data security
  6. Data retention
  7. International data transfers
  8. Your rights
  9. Contacting us

1. 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 permanently removed (anonymous data).

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
  • Company Data includes profession, company name, business address
  • Contact Data includes billing address, email address and telephone numbers
  • 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 our websites or App.
  • Usage Data includes information about how you use our website and services.
  • Alerts and Communications Data includes your preferences in receiving alerts and regulatory updates 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 different purposes. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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 or App 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 policy.

2. 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 Identity, Contact and Company Data by filling in forms or by corresponding with us by post, email or otherwise.

Automated technologies or interactions. As you interact with our websites, 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 and public sources as set out below:

We may receive information you provide via our website when you register for our alerts service including Identity, Contact, Company, Alerts and Communication data. Our Corporate website is managed by Emperor and Euroland.com manages our alert services. Please see Euroland Privacy Policy  for more information about how they process your personal data.

Technical Data from the following parties:

  • Analytics, storage, tools and media providers based in and outside the EU;
  • IP tracking service providers based within the EU;
  • automated quality control tools based within the EU;
  • automated security and compliance tools based outside the EU;
  • email distribution and survey providers based outside the EU;
  • Identity and Contact data from providers of data feeds and hosting services provided inside the EU and outside of the EU.

3. How we use your personal data

We will only process personal data where we have a genuine need to do so and in line with our obligations under data protection laws.  Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform a contract we are about to enter into or have entered with you.
  • Where it is necessary for our legitimate interests (or your legitimate interests or those of a third party).
  • With your consent.
  • Where we need to comply with a legal or regulatory obligation.

Shareholders

If you are a shareholder of the Company, we may process Identity and Contact data as well as information about your share holdings.

We may also process your personal data where necessary to comply with legal requirements placed upon us, such as the Companies Act, Stock Exchange requirements, financial crime regulations and taxation laws.

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 have set out below 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.

  • To manage our relationship with you which will include (a) notifying you about changes to our terms or privacy policy (b) to keep you informed about news and events, including regulatory news related to Moonpig Group PLC we may process your Identity, Contact, Alerts and Communications data for the performance of our contract with you, where it is necessary to comply with our legal obligations or where it is necessary for our legitimate interests (e.g. to keep our records updated).
  • To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) we may process your Identity and Contact data, and Technical data (e.g. Cookies) where it is necessary for our legitimate interests (e.g. for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) or where it is necessary to comply with a legal obligation.

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 our website may become inaccessible or not function properly. For more information about the cookies we use, please see our Moonpig Group plc Cookie Policy.

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.

4. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out above.

Internal third parties:

These are companies within the Moonpig Group. Your personal data will also be hosted in Ireland.

External third parties:

Service providers

These providers support Moonpig in carrying out our activities and services to you. We only give them the parts of your personal data that they need. And we make it clear to them that they must keep your personal data safe and only used for these services.

These are:

  • Third party service providers (such as our website hosts) in order to run the service and administer your account
  • For the purposes of providing you a service, emails or similar alerts
  • Shareholder registrar and tracing agents service providers
  • Fraud prevention companies
  • Information technology (hardware and software) companies for the purpose of data storage and analysis

The Authorities

When it’s necessary for us to share some parts of your personal data with authorities such as regulatory authorities or the police, for example, to help prevent fraud and crime, we only share what is legally necessary. When we do give this data to the authorities, it’s their responsibility to protect your information.

Other

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 policy.

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.

5. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. We also 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.

6. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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 unauthorised 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, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us at [email protected].

7. International data transfers

Moonpig transfers your personal data to other Moonpig companies in the Moonpig Group and service providers outside the European Economic Area (EEA). The service providers that Moonpig works with must prove to us that they have the same high standards around protection of your data as Moonpig.

Where Moonpig transfers your personal data outside the EEA, we make sure that there are rules in place to protect your data. This means that Moonpig either has contractual clauses approved by the European Commission in our contracts with parties outside the EEA, or Moonpig will rely on European Commission adequacy decisions.

8. Your rights

You have personal data rights. These are 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, when 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 for erasure for specific legal reasons which will be notified to you, if applicable, when you make 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 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:

  • If you want us to establish the data's accuracy.
  • Where our use of the data is unlawful, but you do not want us to erase it.
  • 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.
  • 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.

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. Alternatively, we could refuse to comply with your request in these circumstances.

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

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

9. Contacting us

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Moonpig.com Limited

Email address: [email protected]

Postal address: Herbal House, 10 Back Hill, London, EC1R 5EN

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk) or the Data Protection Commission (DPC), the Ireland regulator for data protection issues (https://www.dataprotection.ie/). We would, however, appreciate the chance to deal with your concerns before you approach the ICO/DPC so please contact us in the first instance.

We keep our Privacy Policy under regular review. This version was last updated February 2024. We reserve the right to modify this Policy at any time. Changes to this Policy will be posted on the Site. You should review this Policy frequently. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Our websites may include links to third-party websites, plug-ins, and applications. 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 websites, we encourage you to read the privacy policy of every website you visit.