Privacy Policy

Introduction

Welcome to Squirrelled Limited’s (“Squirrelled”, “we”, “us”, “our”) privacy policy.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information about who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

Data Controller

Squirrelled is the data controller and is responsible for certain personal data that we collect in relation to users of our website www.squirrelled.com and our app (together the "Platform"). We facilitate the payment of cash back to Squirrelled members, and to their nominated Schools/PTAs, in accordance with our terms and conditions.

Capitalised terms are either defined below or within our terms and conditions.

This privacy policy applies to ‘you’ whether you are:

• A member who has registered an account with the Platform ('Member');
• A representative of a school or PTA that has registered an account with the Platform as a School or PTA (‘School/PTA’), (‘School/PTA Administrator’).

A school or PTA must be registered in the UK

• A visitor to the Platform whether you are visiting the platform through a browser, via a mobile device or tablet, or through an app ('Visitor').

If you have any questions about this policy or about how we handle your data, please contact our data privacy team as follows:

Email: support@squirrelled.com

Address: Squirrelled Ltd., Penstraze Business Centre, Truro, Cornwall TR4 8PN

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). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated in March 2025.

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.

Third-party links

This website and our app 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 website, we encourage you to read the privacy policy of every website you visit.

Third-party apps, websites and services

If you use any third-party apps, websites or services to access our services, your usage is subject to the relevant third party's terms and conditions, cookies policy, and privacy policy. For example, if you interact with us on social media, your use is subject to the terms and conditions and privacy policies of the relevant social media platform (Facebook, Instagram etc.).

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 removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Members

• Identity Data: includes name, user identifier, profile photo, date of birth and gender.
• Contact Data: includes email address, telephone, address, where applicable.
• Marketing Data: includes your preferences in receiving marketing communications from us or third parties.
• Profile Data: includes information retained within your account profile such as username and password, feedback, contact history, surveys, information provided in relation to your Donations, your chosen Schools / PTAs, details of purchases you make from retailers, any messages of support.
• Usage Data: information about how you use our Platform, IT, communication and other systems.
• Technical Data: includes your computer’s Internet Protocol (IP) address, your browser type and version, the click history and pages you visit, search terms, the time and date of your visit, the time spent on each page, the device type, operating system, unique device identifiers, device settings, and geo-location data, diagnostic data (the query string data that is triggered when we receive a request to stand down the toolbar and the URL associated with the stand down request event).  
• Transaction Data: details of purchases made with retailers and how these convert to cash back for the Member or Schools/PTAs

School/PTA Administrators
(either organisation representatives or individuals as the case may be)

• Identity Data: includes name username or similar identifier, profile photo, date of birth and gender.
• Contact Data: includes company or personal email address and telephone number, job title and company details where applicable, online presence where applicable.
• Marketing Data: includes your preferences in receiving marketing communications from us or third parties.
• Profile Data: includes your username and password, feedback, and your responses to surveys, your contact history.
• Usage Data: information about how you use our website, IT, communication and other systems.
• Technical Data: includes your computer’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, the device type, operating system, unique device identifiers, device settings, and geo-location data. 

Visitors  

• Technical Data: includes your computer’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, the device type, operating system, unique device identifiers, device settings, and geo-location data. 
• Usage Data: information about how you use our website, IT, communication and other systems

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. 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 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.

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 offences.

Your visibility via the Platform

Please note that when you nominate a School/PTA via the Platform, we may share your first name and first initial of your surname to the School/PTA.  If you do not want us to do this, please use the 'My Account' section on the Platform to tell us you wish to remain anonymous.

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 our products). In this case, we may have to cancel a product you have purchased from us but we will notify you if this is the case at the time.

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 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:
• create an account on our app;
• subscribe to our publications;
• request marketing to be sent to you;
• enter a shopping survey; or
• give us feedback or contact us.
• Automated technologies or interactions. As you interact with our Platform, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

• Automated decision making. As you interact with our Platform, we will automatically collect Profile and Technical Data about your click history and purchasing patterns. We collect this data using cookies, server logs and other similar technologies. We use this data to create profiles of our users in order to serve them more relevant offers and services. No decisions with significant legal or similar effects are made solely through automated processing.
• Third parties. We will receive personal data about you from various third parties such as:
  • analytics providers such as Google;
  • Retailers and affiliate networks in relation to the actions that you carry out on their websites or within their networks;
  • Publicly available sources such as School/PTA directories
  • Social Networking Services such as Facebook, when you sign into our Platform through a Social Networking Service.

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 obligation.
• In limited circumstances where you have given your consent.

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 list below.

1. To register you as a Member and create an account

• Type of Data:
  (a) Identity
  (b) Contact
  (c) Profile
• Lawful Basis:
  Performance of a contract with you

2. To process and execute your request as a Member to raise money for your School/PTA

• Type of Data:
  (a) Identity
  (b) Contact
  (c) Profile
  (d) Transaction
• Lawful Basis:
  Performance of a contract with you

3. To register you or your School/PTA

• Type of Data:
  (a) Identity
  (b) Contact
• Lawful Basis:
  Necessary for our legitimate interests (to facilitate the payment of Donations to Schools / PTAs)

4. To manage our relationship with you as a School/PTA or School/PTA Administrator

May include:
(a) Notifying you about changes to terms or privacy policy
(b) Asking you to leave a review or take a survey

• Type of Data:
  (a) Identity
  (b) Contact
  (c) Profile
• Lawful Basis:
  (a) Performance of a contract with you
  (b) Necessary to comply with a legal obligation
  (c) Necessary for our legitimate interests (to keep records updated and to study how our platform is used)

5. To enable you to complete a survey or carry out a review

• Type of Data:
  (a) Identity
  (b) Contact
  (c) Profile
  (d) Usage
• Lawful Basis:
  (a) Performance of a contract with you
  (b) Necessary for our legitimate interests (to study how Members and School/PTA Administrators use our platform and grow our business)

6. To administer and protect our business and website

Includes: troubleshooting, data analysis, testing, system maintenance, support, reporting, and data hosting

• Type of Data:
  (a) Identity
  (b) Contact
  (c) Technical
• Lawful Basis:
  (a) Necessary for our legitimate interests (business operations, IT services, network security, fraud prevention, restructuring)
  (b) Necessary to comply with a legal obligation

7. To deliver relevant website content and marketing/advertisements

Includes: customizing offers, look of the platform, and measuring advertising effectiveness (including from third parties)

• Type of Data:
  (a) Identity
  (b) Contact
  (c) Profile
  (d) Usage
  (e) Marketing and Communications
  (f) Technical
• Lawful Basis:
  (a) Necessary for our legitimate interests (to study usage, develop services, grow business, inform marketing)
  (b) Consent

8. To use data analytics to improve our website, products, marketing, customer relationships, and experiences

• Type of Data:
  (a) Technical
  (b) Usage
• Lawful Basis:
  Necessary for our legitimate interests (to define customer types, keep website relevant, develop business and marketing strategy)

9. To make suggestions and recommendations about services of interest to you

• Type of Data:
  (a) Identity
  (b) Contact
  (c) Technical
  (d) Usage
  (e) Profile
  (f) Marketing and Communications
• Lawful Basis:
  (a) Necessary for our legitimate interests (to develop products/services and grow business)
  (b) Consent

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

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 and offers may be relevant for you (we call this marketing).

If you are a Member, you may receive marketing communications from us if you have consented for us to send you this information or if you have requested information from us or purchased products from us and you have not opted out of receiving that marketing.

We will also ask if you consent to receiving email updates from Schools/PTAs about the impact of your cash back and other ways to support them including future events, campaigns and appeals. If you opt in to receiving such emails, we will pass your consent preference on to your nominated School/PTA.   Please note that the School/PTA will need to receive your personal data to send you emails you consent to receive.

Opting out

You can ask us to stop sending you marketing messages at any time by using the My Preferences section of the 'My Account' area or by sending an e-mail to support@squirrelled.com clicking the 'unsubscribe' link within any of our marketing emails.

If we contact you by SMS and you no longer wish to be contacted by SMS, please reply to any texts we have sent by texting "STOP" to the number included within the text we originally sent you.

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/ purchase, product experience or other transactions.

If you want to change your preferences for a School/PTA use your data (to contact you or otherwise), please contact the School/PTA directly.

Cookies

Please note though that without cookies we cannot track or facilitate payments to you or your Schools / PTA. If you decide to block our cookies this may mean that many of the features of the Platform will not work. Due to the way in which the Platform and our services are provided we currently do not provide alternative ways for the service to be provided without cookies.

Therefore, although 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, we will not be able to provide our services to you and make payments to you or your Schools / PTA.

For more information about the cookies we use, please see our Cookie Policy.

Affiliate Networks

When you click through to a retailer from our Platform, your browser redirects via an affiliate network which may drop a cookie on your device. The cookie stores tracking information so that when you visit a retailer via our Platform, any purchases made will result in the retailer reading this information. The retailer will then send us information about your purchases, at which point we can raise a Donation for your Schools / PTAs. We recommend that you enable cookies in your browsers to make full use of our Platform in order to ensure that any purchases are recorded and so that we can ensure that the Donation is made to the Schools / PTAs.

Whilst the affiliate network cookie isn’t dropped by us, we want to tell you about it before you use our Platform to make a transaction. For more information about the cookies the affiliate networks use, please see  www.squirrelled.com/terms/cookies

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.

3. Disclosures of your personal data

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

• External Third Parties
  • Service providers acting as processors who provide services such as payment processing services, competition and reward services, and IT and system administration services.
  • Affiliate networks and retailers – to facilitate the payment of cashback to Schools/PTAS at your request in accordance with our terms and conditions, and to enable us to investigate claims or other queries on your behalf in relation to cashback

Please note that in relation to Schools/PTAs - unless you choose to be anonymous to Schools/PTAs when you nominate them, we will share your personal data with them. When we pass your information to Schools/PTAs, they also become a separate data controller with respect to such personal data. This means that they are responsible for their own compliance with data protection laws when they use your personal data, and all such use is subject to the School/PTA s own privacy policy. We are not responsible for School/PTAs use of your personal data or the School/PTAs compliance with applicable laws.

• In limited circumstances, if you are the person listed as the administrator for a School/PTA and this School/PTA has been referred to Squirrelled by a third party, we may share your name and email address with this third party to ensure our records are up to date. 
• Marketing companies and online advertising – Helping us to manage our electronic communications to you and to help us show you the advertising you are most likely to be interested in, companies that provide marketing and advertising assistance (including email matching services, management of email marketing operations, mobile messaging services such as SMS, and services that deploy advertising on the internet or social media platforms, such as Facebook, Instagram, Google) as well as analysis of the effectiveness of our advertising and communications campaigns.
• Third Party Advertisers such as Awin who provide content on the Platform. For more information on the purpose and scope of the data collected and its further processing and use by the provider as well as your related rights and setting options to protect your privacy, please refer their Services Privacy, as outlined above re ‘Third Party Links’  and please note that Squirrelled has no control over this site or the privacy policy.  
• Software solutions providers such as Impact Tech, Inc. so that they can offer services such as optimisation and management of partnerships. We may share your email address with these entities so that they can match it with the lists of users provided to them by retailers who participate in our Platform. Where a match is confirmed, we may then tailor the advertisements that you see when using our Platform or social media channels or to send you marketing emails provided always that you have not opted-out or chosen to not see personalised content. You can ask us to stop sending you marketing messages at any time by using the My Preferences section of the 'My Account' area or by sending an e-mail to support@squirrelled.com or clicking the 'unsubscribe' link within any of our marketing emails.
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom.

• 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.

4. International transfers

We may share your personal data with other entities within our group or with external third parties based outside the UK.

Whenever we transfer your personal data out of the UK, 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.
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. 

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

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. 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.

To enable us to make payments to you, members will need to provide a valid UK bank account that can receive cashback when due. Banking information is encrypted when in transit and at rest. Data encrypted in transit uses TLS protocols and TLS certificates provided by Cloudflare.

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 from us by contacting us.

7. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below (Your Legal Rights) to find out more about these rights.

If you wish to exercise any of these rights please contact our privacy team: Either send a mail to support@squirrelled.com  Or you can visit the ‘Squirrelled Data’ section of the ‘My Account’ area of the Platform.

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 a number of requests. In this case, we will notify you and keep you updated.

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 / deletion 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. To request account deletion and erasure of your personal data, please contact support@squirrelled.com

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:

• 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.

Last updated: March 2025