Privacy policy

A. Introduction

We are LABEL THERAPY (and we refer to ourselves as “LABEL THERAPY”, “we” or “us” or “our” in this document).

We are committed to protecting your privacy. We ask that you please read the following carefully to understand our views and practices regarding your personal data and how we, as data controller of your personal data, will treat it.

We will only use the information that we collect about you lawfully (in accordance with the Data Protection Act 1998 and other applicable data protection laws in the UK).

B. The Information We Collect

Data we collect from you directly

When you register to use the Sites we will ask for the following information: your name, email address, password, IP address and postcode. We may also ask you to provide your age, your phone number, your street address and possibly certain other personal details such as gender or where you heard about us.

In addition, you will be able to register for the third-party website of a Retailer via LABEL THERAPY. If you insert any information in such third party registration form we may use such information in accordance with this Privacy Policy. However if such third party registration form includes payment information, this will not be retained and we shall not make any use of such information except to submit such information to the applicable third party together with the entire registration form.

We will also ask you to provide data as you use the Sites so that we can provide the certain aspects of the Services. For example:

If you place an order for one of the Retailers, we will ask you for your login details for that Retailer (or you can register for that Retailer via our Website).

If you participate in our cashback programme, we will collect and retain your PayPal account so we can pay you and we may use your Retailer login details to verify and confirm completion of your order (or to check other eligibility criteria) before paying cashback earned. In simple terms, we may need to check you have actually bought certain goods, before paying out under the cashback programme for those goods.

Data we collect from your activity on the Sites

As you use the Sites and personalise your account, we collect data about your activity on the Sites. This includes things like:

  • Information on what you buy and how you use the Sites, such as:

    • information on baskets you have sent on to a Retailer;

    • your favourites;

    • your sorting preferences;

    • your product swaps, basket ‘splits’ and store ‘switches’;

    • other details about your shops and how you have used the Sites;

    • for each page viewed on a third-party Retailer website via the Sites, we collect information on the page visited (page URL and title) and information as to how you used that page, although except for that, except as it may be requested from you as part of the Services, we do not collect any personal data about you from a third-party Retailer website and/or from your activity on it while you are using the Services;

  • Information about your use of various Sites services;

  • Information about any cashback amounts you have received from our cashback programme;

  • Your communications with LABEL THERAPY;

  • Information about your current location (for users of any LABEL THERAPY App). You may opt out of having this data collected at any time by managing your smartphone location services settings;

  • Other Information related to your use of the Services;

  • Other information related to your activity, such as which website referred you to us;

Data we collect from other sources

We may receive information about you from third party sources, such as data aggregators and from third parties to whom you have given permission to share your information or from whom you have given us permission to request your information. For instance, by registering for the Sites using Facebook or another social network, you grant permission to that network to share your details. Depending on the network rules and your settings on it, this may include data such as your date of birth, your marital status, the number of people in your household and other information.

Sensitive Personal Data

Sensitive personal data is defined by the Data Protection Act and includes details such as information related to your health, sexual orientation, religion, race or ethnic origin. For the most part, we will not need any Sensitive Personal Data in order to provide our services and we will not request it. However, we may be able to assume sensitive personal data about you from the information you provide. By letting us have any sensitive personal data, you expressly consent to us using and telling others about any of your sensitive personal data so we can provide you with the goods or services requested by you and engage in commercial activities in the way set out in this Privacy Policy.

C. How We Use the Information We Collect

We use the personal data we collect to provide the Services, to customise and improve your LABEL THERAPY experience, to make your experience as enjoyable and efficient as possible and for commercial purposes.

Use of Information to Provide the Services

Certain information is required in order for the Services, or certain features of the Services, to operate.

Here are some specific examples of information used to provide the Services.

  • Your email address and password allows us to recognise you when you return so that we can provide you with a faster service and a personal user account.

  • Your postcode allows us to identify which Retailers deliver to your area and what products are available at those Retailers. Products in particular Retailers do sometimes vary by locality.

  • We use your IP address to prevent any spam, fraud or abuse of our site.

  • We use your login data for Retailers:

    • to allow you to place an order or book a delivery slot with one of the Retailers,

    • to import your favourites from any given Retailer and to update these favourites lists when you visit LABEL THERAPY

    • to confirm completion of orders placed (including collecting information about your purchase from the third-party Retailer website, such as the items you ultimately received, the basket total and delivery date). This may be to work out whether you may be eligible for Cashback on one of our Cashback Programmes or for other verification reasons.

  • To facilitate your registration to a Retailer, we may provide you with the ability to register for a relevant third party website of a Retailer through the Sites. If so, we may pre-populate certain fields in the registration form for that third party website for you. If we do so, it will be for fields for which we already hold your information, such as your name, postcode and email address. You always have the opportunity to delete any fields that we pre-populate.

Use of Information to Customise and Improve the LABEL THERAPY Experience

We want your shopping experience on LABEL THERAPY to be as enjoyable as possible. We will collect the data about your shopping activities and preferences to customise your account (in addition to how you customise it yourself) and to enable us to provide an efficient and user-friendly service. We will also use it to improve the quality of the site.

Here are some specific examples of how we use your data:

  • We keep details of your favourites from any of the Retailers (if you have chosen to import them to your LABEL THERAPY account), details of items you have added to favourites and details of previous baskets of goods you have ordered in your favourites list. This will allow you to shop more efficiently on future visits.

  • We keep a record of the contents of your baskets of goods between shopping sessions. This allows you to continue shopping sessions that you may have stopped midway with no need to add again all the items that you already placed in your basket.

  • We may keep a record of certain of your preferences such as sorting order of items and the last shelf you accessed, so you don’t need to reset these preferences every time you start shopping.

  • We keep a record of your login details for the Retailers to make it faster for you to place orders or book delivery slots in the future so that you do not continually have to re-enter such details. We also keep these details to ensure you are able to benefit from our cashback programmes as we use them to verify your eligibility, as we set out above. If you have chosen to import your favourites from a Retailer, we will use your login details for that Retailer in order to automatically update any imported Retailer Favourites lists when you visit the Sites.  If you do not wish to have your imported Retailer Favourites lists automatically updated, you can easily opt out updating your Import Favourites preferences in the “My Account” section of the Sites at any time.

  • Paying attention to how you use the Sites help us to develop improvements to the Sites and the Services.

  • If you have been referred to us by a third-party website, we may keep a record of the website that referred you so that we may work out which websites refer more or less users to our Sites. We may also have referral arrangements with certain third-party websites and referrers and we may use this data to fulfil obligations that we may have to these third-party websites or referrers.

  • We collect and track individual and aggregate information about shopping habits, products and service preferences and selections which users have made and the like. We use this information for the personalisation or general improvement of the Services, but also for the purpose of business research. You can see more about aggregate information below.

  • We collect and track individual and aggregate connection information such as browser type and version, operating system and platform; other software and hardware information and the like. We use this information to understand how and when our users access our services, and so we can further develop our Sites and Services to suit.

Use of Information for Commercial Purposes

LABEL THERAPY does not charge non-commercial users for use of the Sites. When you use a service like Gmail, you ‘pay’ for the service by allowing Google to scan your emails and use the information they find to target ads at you. When you use the MSM comparison service, you ‘pay’ for the service by allowing us to use the data we collect about you and about your use of Sites, which we then anonymise, aggregate and sell. In terms of data which is personal to you however, we earn revenues from this (which allows us to keep the Sites online and totally free to our non-commercial users) through industry standard sources and methods including advertising sales which may be targeted to you (including online behavioural advertising, including and personalised retargeting advertising, ) and through the sale of business intelligence data (which is anonymised).”

Here is how your information is used for this:

  • We use information about your activity on our site, including information about your current location when using the App, in order to present you with targeted advertising—that is, product information, offers and promotions that we think may be interesting to you and that you might like. Without targeting, you will still see advertisements; they are just less likely to be relevant.

  • We share information with certain carefully selected third party partners so that they can:

    • present you with advertisements and promotional offers that are relevant to you and your interests on both LABEL THERAPY and other sites based on your activity on LABEL THERAPY or, alternatively;

    • to present you with advertisements on LABEL THERAPY based on your activity on other websites. For example, you may see ads for products you viewed on another website while browsing LABEL THERAPY.

  • For more information on data sharing, please see the “Data Sharing” section.

  • We collect and may display or use for the purposes of marketing and advertising the Sites, Services or ourselves, any testimonials you provide us with about the Sites, the Services or ourselves – and we may append to the testimonial your first name (but not your surname) and general geographic location (e.g. City or locale).

  • We collect data on your  (and other users’) activity in respect of products and how users shop online in order to develop business intelligence insights on consumer behaviour in general, in respect of a particular brand or product and other areas. This data (which is anonymised and is based on a statistical analysis of the activity of thousands of users) is sold or provided to LABEL THERAPY customers which include journalists, brands, retailers, researchers and others.  Examples of data we might look at are: which products you seem to prefer; which  products you have added to (or removed from) your LABEL THERAPY favourites list and to or from the lists you have imported from Retailers using our Import Favourites service; products you tend to purchase together; how you use the site (e.g. in what order consumers do their online shopping) and other areas.  For more information, see the section on Aggregate Information, below.

Use of Your Email Address

We use your email address to communicate with you. Some of these are service emails and are so we can communicate with you about Sites updates or your activity on the Sites. For instance, we may send you service emails:

  • after registration for the Services or any cashback programme, notifying you of your registration details;

  • after you have sent a basket of goods to a Retailer, giving you details about that including regarding applicable cashback amounts;

  • to send you information which you have asked for; and

  • to contact you about the status of ratings or reviews you have submitted using our Services.

In addition, from time to time we may email you marketing emails with Sites news and updates or details of sales offers or promotions. These may be marketing for the Sites itself or on behalf of third parties. We may also contact you for market research purposes, either for commercial purposes or so we can get feedback about the Sites.

Your acceptance of the LABEL THERAPY Terms of Use means that you are giving us consent to send you these emails. However, you can easily opt out of receiving marketing emails by clicking “unsubscribe” in the relevant email or by updating your email preferences in the “My Account” section of the Sites at any time. Even if you opt out, we will still send you service emails about the Sites itself, your account and your activities on the Sites.

Aggregate Information

Aggregate information is data we collect about a group or category of products, services or users, from which individual user identities have been removed and from which it is not possible to work out individual customer identities. In other words, information about how you use a service may be collected and combined with information about how others use the same service, but all such information will be anonymised and no identifying information will be included in the resulting data.

Aggregate data helps us to understand trends and customer needs so that new products and services can be considered and so that existing products and services can be tailored to customer desires. We use and disclose anonymised aggregate information to provide other products and services, as well for the purposes of evaluating and improving our existing products and services. We also sell such aggregate information, both via our business insights website and through other channels.

D. Security Measures

All of the information we collect about you is stored on our secure servers and will be held securely in accordance with our internal security policy and the law. For example, we use secure encryption to hold passwords (e.g. the password allocated as part of the registration process – which may later be changed) or your login details for a Retailer (if you authorise us to save this information).

We may send your information internationally including to countries outside the European Economic Area. While we will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, some places outside of the EEA may not have adequate data protection laws at all or may offer differing levels of protection of personal information which are not as high as in the UK. By submitting your data to us, you acknowledge that provided we have used your data in the ways set out in this Privacy Policy, we cannot be held responsible for any use of your data by third parties who receive and process your data.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; 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 unauthorised access.

E. Technology

LABEL THERAPY and its partners and service providers use cookies to provide the Services, to customise and improve your LABEL THERAPY experience and for commercial purposes. You can find more information on the cookies used by LABEL THERAPY, our partners, service providers and other third parties as well as how to manage your cookie choices in our Cookie Policy.

F. Data Sharing

There are a number of instances in which LABEL THERAPY may share your personal information. This may be in order to allow us to operate the Sites, for corporate or statutory purposes or as part of a partnership with a third party. All recipients of your personal data are required to treat it in accordance with the Data Protection Act 1998 and other applicable data protection laws in the UK and this Privacy Policy.

Your acceptance of the LABEL THERAPY Terms of Use means that you are giving us consent to share your personal information with our carefully selected third party partners. However, you can easily opt out of this sharing of your personal information by updating your preferences in the “My Account” section of the Sites at any time. Even if you opt out, we will still share your personal information as needed to operate the Sites or as is needed for corporate or statutory purposes.

Operating Purposes

• We may share your personal information to any member of our group of companies, which means any subsidiaries of LABEL THERAPY Limited, or its ultimate holding company and its subsidiaries.

• At times we work with other companies who help us to provide the Services to you or provide other support services pertaining to the operation of the Sites. These companies receive only the personal information required in order to provide services, and are not allowed to use that information for anything aside from providing the services.

  • We reserve the right to investigate suspected violations of the Terms of Use of the Sites or illegal, fraudulent or inappropriate behaviour on the Sites; and to engage in activities needed to protect the rights, property, or safety of ourselves, of our users, or of others. To that end, and to the extent necessary to achieve the forgoing, we may exchange information with other companies and organisations, including but not limited to Retailers, our affiliates and partners and law enforcement agencies.

Corporate and Statutory Purposes

  • We may transfer our databases containing your personal information if we sell our business or part of it and engage in another similar corporate transaction.

  • We will share personal information where we are required to share your personal data in order to comply with any legal obligation.

Third Party Partnerships

We may share your personal information with other third parties with whom we have a partnership.

H. This Privacy Policy

Please note that this Privacy Policy forms part of the Terms of Use for use of the Sites, Browser Extension and the Services and forms part of the Agreement between you and us. The terms defined in those Terms of Use are used in the same way in this Privacy Policy. Updates to this Privacy Policy are dealt with in the same way as in those Terms of Use.