TOGETHER PRICE PRIVACY POLICY

 

1.OUR APPROACH TO PRIVACY

    1. Together Price Limited (“Together Price“, “we“, “our” or “us“) is committed to protecting and respecting your privacy. This Privacy Policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you (“personal information“) and information regarding our use of cookies and similar technologies. 
    2. This Privacy Policy applies to the Together Price Service. Please ensure that you have read this Privacy Policy and understood how we collect, store, use and disclose your personal information before accessing or using the Together Price Service.
    3. We operate a platform that facilitates the sharing of certain online services between users by allowing them to set up and join groups to communicate, split the cost of subscribing to the online service and arrange payment, which we make available through our website www.togetherprice.com (the “Together Price Service“). 

2.WHO IS RESPONSIBLE FOR THE USE OF YOUR PERSONAL INFORMATION

      1. Together Price Limited is the controller of the personal information we hold about you in connection with your use of the Together Price Service. This means that we determine and are responsible for how your personal information is used.

3.PERSONAL information we collect FROM you when you use the TOGETHER PRICE SERVICE, and how we use it

    1. We collect personal information that you voluntarily submit directly to us when you use the Together Price Service. This can include information you provide to us when you set up an account on the Together Price Service, fill in a form on the Together Price Service, create or edit your user profile on the Together Price Service, correspond with us by phone, e-mail or otherwise, subscribe to our mailing lists, newsletters or other forms of marketing communications, or use some other feature of the Together Price Service. 
    2. We will indicate to you where the provision of certain personal information is required in order for us to provide you certain features of the Together Price Service. If you choose not to provide such personal information, we may not be able to provide those parts of the Together Price Service to you or respond to your other requests.
    3. When you use the Together Price Service, the categories of information we collect may include:
      1. your contact details, such as your name, email address and phone number;
      2. information you upload to personalise your profile, such as your profile picture; 
      3. the online services for which you have created or joined a group to share access (a “Sharing Group“);
      4. your date of birth;
      5. your payment details; 
      6. your country of residence; and
      7. how you interact with the Together Price Service.
  1.  

We use this information to operate, maintain and provide to you the features and functionality of the Together Price Service, to address your questions and concerns, to contact you and to help us develop new products and services.

      1. The table at Annex 1 sets out further detail about the categories of personal information we collect about you and how we use that information when you use the Together Price Service, as well as the legal basis which we rely on to process the personal information and recipients of that personal information.

4. Information we collect about you automatically

    1. We also automatically collect personal information indirectly about how you access and use the Together Price Service, and information about the device you use to access the Together Price Service. For example, we may collect:
      1. information about the features you use and the pages you view on the Together Price Service;
      2. information about your device (such as your IP address, device identifier, device type, model and manufacturer); and
      3. information about your usage patterns (such as how often you use the Together Price Service and your language settings).

We use this information to provide you the features and functionality of the Together Price Service, to monitor and improve the Together Price Service and to develop new products and services.

      1. The table at Annex 2 sets out further information about the categories of personal information we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal information and recipients of that personal information. 
      2. We generally collect personal information automatically through SDKs, software provided to us by third party analytics platforms that has been integrated into the Together Price Service. If you would like to opt out of us collecting information in this way, please contact us using the details at the end of this Privacy Policy.
      3. We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.
      4. We may anonymise and aggregate any of the personal information we collect (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving the Together Price Service and developing new products and features. We may also share such anonymised and aggregated information with others. 

5.How long will we store your personal information

      1. We will usually store the personal information we collect about you for no longer than necessary for the purposes set out in Annex 1 and Annex 2, and in any event for no longer than 6 years after you delete your account on the Together Price Service, in accordance with our legal obligations and legitimate business interests. 
      2. We may, however, need to retain your personal information for longer if we are required to do so by law.

6.RECIPIENTS OF PERSONAL INFORMATION

      1. In addition to the recipients listed in Annexes 1 and 2, we may also share your personal information with the following (as required in accordance with the uses set out in Annexes 1 and 2):
        1. Service providers and advisors: we may share your personal information with third party vendors and other service providers that perform services for us or on our behalf, which may include providing professional services, such as legal and accounting services, mailing, email or chat services, fraud prevention, web hosting, or providing analytic services. 
        2. Affiliates. Other companies owned by or under common ownership as Together Price, including our subsidiaries (i.e., any organisation we own or control) and our ultimate holding company (i.e., any organisation that owns or controls us) and any subsidiaries it owns.  These companies will use your personal information in the same way as we can under this Privacy Policy.
        3. Purchasers and third parties in connection with a business transaction: your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.
        4. Law enforcement, regulators and other parties for legal reasons: we may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements, including our Terms of Use; and/or (iii) exercise or protect the rights, property, or personal safety of Token, its users or others.

7.Marketing and advertising

      1. From time to time we may contact you with information about our products and services, including sending you marketing messages and asking for your feedback on our products and services. 
      2. Most marketing messages we send will be by email. For some marketing messages, we may use personal information we collect about you to help us determine the most relevant marketing information to share with you. 
      3. We will only send you marketing messages if you have given us your consent to do so. You can withdraw your consent at a later date by clicking on the unsubscribe link at the bottom of our marketing emails or by updating your preferences through the Together Price Service.

8.Storing and transferring your personal information

    1. Security. We implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored by our cloud hosting provider on secure servers. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers.
    2. International Transfers of your Personal Information. The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third party service providers have operations. If you are located in the European Economic Area (“EEA“), your personal information may be processed outside of the EEA including in the United States.
    3. In the instance of such a transfer, we ensure that:
      1. the personal information is transferred to countries recognised as offering an equivalent level of protection; or
      2. the personal information is transferred to certified entities under the EU-U.S. Privacy Shield; or
      3. the transfer is made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission or UK Information Commissioner. 

If you wish to enquire further about these safeguards used, please contact us using the details set out at the end of this Privacy Policy. 

9.Your rights in respect of your personal information

    1. In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:
      1. Right of access. You have the right to obtain:
        1. confirmation of whether, and where, we are processing your personal information;
        2. information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;
        3. information about the categories of recipients with whom we may share your personal information; and
        4. a copy of the personal information we hold about you.
      2. Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.
      3. Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay. 
      4. Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified. 
      5. Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.
      1. You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case.  You can object to marketing activities for any reason. 
      2. If you wish to exercise one of these rights, please contact us using the contact details at the end of this Privacy Policy.
      3. You may also review and edit some of the personal information you have submitted to us through the appropriate functionality on the Together Price Service.
      4. Due to the confidential nature of data processing we may ask you to provide proof of identity when exercising the above rights. This can be done by providing a scanned copy of a valid identity document or a signed photocopy of a valid identity document.
      5. We will seek to respond to any request relating to your rights within one month of receipt of such request. 
      6. Where, given the complexity of the claim or the number of requests received, the above deadline cannot be met, we will inform you of the extended deadline in which we will respond to your request. Such extension may not be more than two months from the date on which we notify you that an extension is required. 
      7. Where we do not follow up on your request, we will inform you within the one month deadline of the grounds on which we have based our decision and of you right to refer a complaint to your national data protection authority.

10.Cookies and Similar Technologies used on our website

      1. Our website uses cookies and similar technologies (such as pixels and Local Storage Objects (LSOs) like Flash objects or HTML5) to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to monitor and analyse how you use and interact with our website so that we can continue to improve our website. It also helps us and our advertising partners to determine products and services that may be of interest to you, in order to serve you targeted advertisements.
      2. Cookies are pieces of code that allow for personalisation of our website experience by saving your information such as user ID and other preferences. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. 
      3. We use the following types of cookies:
        1. Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
        2. Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. We may use third-party analytics tools such as Google Analytics, to help us measure traffic and usage trends for the Service and to understand more about the demographics of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners, and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout.  
        3. Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
        4. Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it, and the marketing messages we send to you more relevant to your interests. We may also share this information with third parties who provide a service to us for this purpose.
        5. Third party cookies. Please be aware that advertisers and other third parties may use their own cookies tags when you click on an advertisement or link on our website. These third parties are responsible for setting out their own cookie and privacy policies.
      4. Please see Annex 3 for more information about the cookies we use on the Together Price Service.
      5. The cookies we use are designed to help you get the most from the website but if you do not wish to receive cookies, most browsers allow you to change your cookie settings. Please note that if you choose to refuse all cookies you may not be able to use the full functionality of our website. These settings will typically be found in the “options” or “preferences” menu of your browser. In order to understand these settings, the following links may be helpful, otherwise you should use the “Help” option in your browser for more details.
        1. Cookie settings in Internet Explorer
        2. Cookie settings in Firefox
        3. Cookie settings in Chrome
        4. Cookie settings in Safari web and iOS.
      6. If you would like to find out more about cookies and other similar technologies, please visit www.allaboutcookies.org or the Network Advertising Initiative’s online sources at www.networkadvertising.org
      7. Please note that deleting or blocking cookies may not be effective for all types of tracking technologies, such as Local Storage Objects (LSOs) like HTML5.

11.Tracking Technologies used in our emails

      1. Our emails may contain tracking technologies that provide us with information about your interactions with our emails, including identifying if and when you have opened an email that we have sent you, how many times you have read it and whether you have clicked on any links in that email. This helps us measure the effectiveness of our marketing email campaigns, make the emails we send to you more relevant to your interests and to understand if you have opened and read any important administrative emails we might send you. 
      2. Most popular email clients will allow you to block these technologies by disabling certain external images in emails. You can do this through the settings on your email client – these generally give you the option of choosing whether emails will display “remote images”, “remote content” or “images” by default.
      3. Some browsers also give you the option of downloading and installing extensions that block tracking technologies.

12.Interest Based Advertising

      1. We participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history and use of the Together Price Service. We may share, or we may permit third party online advertising networks, social media companies and other third party services to collect information about your use of the Together Price Service over time so that they may play or display ads of the Together Price Service, on other websites, apps or services you may use (including Facebook), and on other devices you may use. 
      2. Typically, but not always, this information is collected through cookies and similar tracking technologies. These third parties may collect mobile identifiers, such as the ID for Advertising for iOS (IDFA), Google Advertising ID, as well as your device’s IP address, information about other applications on your device, your location, information about your use of the Together Price Service and information about which adverts you have seen or clicked on.
      3. We and our third party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. 
      4. We may also use certain forms of display advertising and other advanced features through Google Universal Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third party cookies together to inform, optimize, and display ads based on your past visits to the Service.  You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences or by vising NAI’s online resources at http://www.networkadvertising.org/choices.   
      5. We and our third party partners may also link your various devices so that content you see on one device can result in relevant advertising on another device. We do this by collecting information about each device you use when you are logged in to the Together Price Service. We may also work with third party partners who employ tracking technologies, or the application of statistical modelling tools, to determine if two or more devices are linked to a single user or household. We may share a common account identifier (such as user ID) with third party advertising partners to help recognise you across devices. We and our partners can use this cross-device linkage to serve interest-based advertising and other personalised content to you across your devices, to perform analytics and to measure the performance of our advertising campaigns. 
      6. You may be able to limit the use of these identifiers for interest-based advertising on a particular device through the settings on your device by selecting “limit ad tracking” (iOS) or “opt out of interest based ads” (Android). You may also be able to opt-out of some, but not all, interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.     
      7. To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit:
        1. the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices;
        2. the DAA’s resources at www.aboutads.info/choices; and/or 
        3. Your Online Choices at www.youronlinechoices.eu.  
      8. Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s or Your Online Choices online resources will only opt you out from receiving interest-based ads on that specific browser or device, but you may still receive interest-based ads on your other devices. You would need to perform the opt-out on each browser or device you use. 
      9. Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or devices, or use another operating system, you will need to opt-out again. 
      10. Please note that opting out of interest-based advertising does not mean you will no longer see advertising on your device – it just means that adverts may no longer be tailored to your interests. 

13.LINKS TO THIRD PARTY SITES

      1. The Together Price Service may, from time to time, contain links to and from third party websites, including those of other users, our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.

14.OUR POLICY TOWARDS CHILDREN

      1. The Together Price Service is not directed at persons under 18 and we do not knowingly collect personal information from any persons under 18. If you become aware that your child has provided us with personal information, without your consent, then please contact us using the details below so that we can take steps to remove such information and terminate any account your child has created with us.

15.CHANGES TO THIS POLICY

      1. We may update this privacy policy from time to time and so you should review this page periodically. When we change this privacy policy in a material way, we will update the “last modified” date at the end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.

16.NOTICE TO YOU

      1. If we need to provide you with information about something, whether for legal, marketing or other business related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on the Together Price Service. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this privacy policy.

17.CONTACTING US

    1. Please contact support@togetherprice.com if you have any questions, comments and requests regarding this Privacy Policy. 
    2. If we are unable to deal with any issues you raise with us, you also have the right to lodge a complaint with your national data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
    3. This privacy policy was last modified on July 2019.

 

ANNEX 1 – PERSONAL INFORMATION YOU PROVIDE TO US

Category of personal information

How we may use it

Legal basis for the processing

Recipients of personal information

Contact information such as your phone number and e-mail address.

We may use this information to set up and authenticate your account

The processing is necessary for the performance of a contract with you and to take steps prior to entering into a contract with you.

We may share this information with the following:

  • If your account has been created before January 2019, we may share your personal information with Lemonway SAS, our payment services provider, in order to identify you so that you can make and receive payments through the Together Price Service.
  • If your account has been created after January 2019, we may share your personal information with Stripe Payments Europe, Ltd, our current payment services provider, in order to identify you so that you can make and receive payments through the Together Price Service.
  • Sendgrid, Inc, our email platform, and Nexmo Inc, our SMS messaging platform, for the purpose of sending you service related and marketing emails and messages.
  • Freshworks, Inc, the provider of our customer support platform, in order to process any customer support queries you might submit to us. 

 

We may use this information to deal with enquiries and complaints made by or about you relating to the Together Price Service.

The processing is necessary for our legitimate interests, namely administering the Together Price Service, and for communicating with you effectively to respond to your queries or complaints.

 

We may use this information to communicate with you, including sending service-related communications.

The processing is necessary for the performance of a contract with you.

We may use this information to send you surveys or requests for feedback about your experience of the Together Price Service.

We will only use your personal information in this way to the extent you have given us consent to do so.

We may use this information to send you unsolicited marketing communications in accordance with your preferences. 

We will only use your personal information in this way to the extent you have given us consent to do so. 

Profile information, such as your profile picture, date of birth, gender, country and city of residence. 

We may use this information to create and display your profile on the Together Price Service

The processing is necessary for the performance of a contract with you.

If your account has been created before January 2019, we may share your country and city of residence and date of birth with Lemonway SAS in order to identify you so that you can use the wallet functionality on the Together Price Service securely.


If your account has been created before January 2019, we may share your date of birth with Stripe Payments Europe, Ltd, in order to help identify you so that you can send and receive payments securely through the Together Price Service.


We may also share this information with Freshworks, Inc, the provider of our customer support platform, to the extent required to process any customer support queries you might submit to us. 

We may use this information to help match you with other users in accordance with the functionality of the Together Price Service.

The processing is necessary for the performance of a contract with you.

Your interests and subscriptions, such as online services to which you have subscribed, the kinds of films and series you like, music tastes, whether you like computer games and other activities that you might like to do. 

We may use this information to tailor the content that is made available to you through the Together Price Service to ensure that it is relevant to your interests.

The processing is necessary for our legitimate interests, namely tailoring the Together Price Service so that it is more relevant to our users.

 

We may use this information to help match you with other users in accordance with the functionality of the Together Price Service.

The processing is necessary for the performance of a contract with you.

Information about your subscription to online services, such as the services to which you have subscribed, your subscription level (i.e. whether you are using a free or premium version of the relevant service, and the number of users that are permitted to access it), the duration of your subscription and your access details.

We may use this information to operate, maintain and provide to you with the features and functionalities of the Together Price Service, namely managing any sharing groups that you may create.

The processing is necessary for the performance of a contract with you.

We may share this information with Freshworks, Inc, the provider of our customer support platform, to the extent required to process any customer support queries you might submit to us. 

We may use this information to ensure that you comply with our Terms of Service and that you do not share access to online subscription services in breach of those subscription services’ terms. 

The processing is necessary for our and third partiers’ legitimate interests, namely ensuring compliance with our and other online service providers’ terms of service. 

We may use this information to tailor the content that is made available to you through the Together Price Service to ensure that it is relevant to your interests.

The processing is necessary for our legitimate interests, namely tailoring the Together Price Service so that it is more relevant to our users.

We may use this information to help match you with other users in accordance with the functionality of the Together Price Service.

The processing is necessary for the performance of a contract with you.

Chat, comments and opinions. When you contact us directly, e.g. by email, phone, or when you participate in a chat on the Together Price Service, we will record your comments and opinions.

We may use this information to operate, maintain and provide to you the social features and functionalities of the Together Price Service.

The processing is necessary for the performance of a contract with you.

We may share any information you provide to us when you contact us with Freshworks, Inc, the provider of our customer support platform, in order to process any customer support queries you might submit to us. 

We may use this information to address your questions, issues and concerns.

The processing is necessary for our legitimate interests, namely communicating with users and responding to queries, complaints and concerns.

We may use this information to develop new products and features available through the Together Price Service or otherwise improve the Together Price Service.

The processing is necessary for our legitimate interests, namely developing and improving the Token App.

Information about your activity on the Together Price Service, such as the groups you join or create and the online subscription services to which you share access through the Together Price Service.

We may use this information to ensure that you comply with our Terms of Service and that you do not share access to online subscription services in breach of those subscription services’ terms. 

The processing is necessary for our and third partiers’ legitimate interests, namely ensuring compliance with our and other online service providers’ terms of service. 

We may share this information with Freshworks, Inc, the provider of our customer support platform, to the extent required to process any customer support queries you might submit to us. 

We may use this information to tailor the content that is made available to you through the Together Price Service to ensure that it is relevant to your interests.

The processing is necessary for our legitimate interests, namely tailoring the Together Price Service so that it is more relevant to our users.

We may use this information to help match you with other users in accordance with the functionality of the Together Price Service.

The processing is necessary for the performance of a contract with you.

Payment and transaction information, such as your credit card, payment authentication code, billing address, and other information such as date and time of your transaction.

We may use this information to process the payments you make or receive through the Together Price Service.

The processing is necessary for the performance of a contract.

We may share this information with the following:

  • If your account has been created before January 2019, we may share your personal information with Lemonway SAS, our payment services provider, in order to identify you so that you can make and receive payments through the Together Price Service.
  • If your account has been created after January 2019, we may share your personal information with Stripe Payments Europe, Ltd, our current payment services provider, in order to identify you so that you can make and receive payments through the Together Price Service.

ID documents, such as your passport and any other documentation you provide to prove your identity. 

We may use this information to verify your identity in connection with the detection and prevention of fraud or financial crime.

The processing is necessary for our and third partiers’ legitimate interests, namely the detection and prevention of fraud and financial crime. 

We may share this information with the following:

  • If your account has been created before January 2019, we may share your personal information with Lemonway SAS, our payment services provider, in order to identify you so that you can make and receive payments through the Together Price Service.
  • If your account has been created after January 2019, we may share your personal information with Stripe Payments Europe, Ltd, our current payment services provider, in order to identify you so that you can make and receive payments through the Together Price Service.

Information received from third parties, such as social networks. If you interact with the Together Price Service through a social network, we may receive information from the social network such as your name, profile information, and any other information you permit the social network to share with third parties. The data we receive is dependent on your privacy settings with the social network.

We may use this information to authenticate you and allow you to access the Together Price Service.

The processing is necessary for the performance of a contract with you.

We may share this information with the following:

  • If your account has been created before January 2019, we may share your personal information with Lemonway SAS, our payment services provider, in order to identify you so that you can make and receive payments through the Together Price Service.
  • If your account has been created after January 2019, we may share your personal information with Stripe Payments Europe, Ltd, our current payment services provider, in order to identify you so that you can make and receive payments through the Together Price Service.
  • Sendgrid, Inc, our email platform, and Nexmo Inc, our SMS messaging platform, for the purpose of sending you service related and marketing emails and messages.

We may use this information to help match you with other users in accordance with the functionality of the Together Price Service.

The processing is necessary for the performance of a contract with you.

We may use this information to tailor the way the Together Price Service is displayed to you (such as the language in which it is presented to you).

The processing is necessary for our legitimate interests, namely tailoring the Together Price Service so that it is more relevant to our users.

Your preferences, such as preferences set for notifications, marketing communications, how the Together Price Service is displayed and the active functionalities on the Together Price Service. 

We use this information to provide notifications, send news, alerts and marketing communications and provide the Together Price Service in accordance with your choices.

The processing is necessary for our legitimate interest, namely ensuring the user receives the correct marketing and other communications, and that the Together Price Service is displayed in accordance with the user’s preferences.

We may share this information with Sendgrid, Inc, our email platform, and Nexmo Inc, our SMS messaging platform, to ensure that we comply with your preferences with respect to the types of emails and messages we send to you.

We use this information to ensure that we comply with our legal obligation to send only those marketing communications to which you have consented. 

The processing is necessary for compliance with a legal obligation to which we are subject.

All personal information set out above.

We may use all the personal information we collect to operate, maintain and provide to you the features and functionality of the Together Price Service, to communicate with you, to monitor and improve the Together Price Service and business, and to help us develop new products and services.

The processing is necessary for our legitimate interests, namely to administer and improve the Together Price Service.

 

 

ANNEX 2 – PERSONAL INFORMATION COLLECTED AUTOMATICALLY

 

Category of personal information

How we may use it

Legal basis for the processing

Recipients of Personal Data

Approximate location information. Other than information you choose to provide to us, we do not collect information about your precise location. Your device’s IP address may however help us determine an approximate location.

We may use information you provide to us about your location to inform and plan our marketing strategy and to monitor and detect fraud or suspicious activity in relation to your account.

The processing is necessary for our legitimate interests, namely informing our direct marketing strategy.

We may share this information with the following:

  • Heap, Inc,, Hotjar Limited, and Google LLC, which provide our analytics platforms, in order to help us understand how visitors use the Together Price Service.
  • Facebook, Inc, and its affiliates, in order to support social sharing and the integration of Facebook services with the Together Price Service.

When you submit a question to us, we may share your IP address with Freshworks, Inc, the provider of our customer support platform, to the extent required to help us process any customer support queries you might submit to us. 

We may use this information to tailor how the Together Price Service is displayed to you (such as the language in which it is provided to you).

The processing is necessary for our legitimate interest, namely tailoring the Together Price Service so that it is more relevant to our users.

We may use this information to help match you with other users in accordance with the functionality of the Together Price Service.

The processing is necessary for the performance of a contract with you.

Information about how you access and use the Together Price Service. For example, how frequently you access the Together Price Service, the time you access the Together Price Service and how long you use it for, the approximate location that you access the Together Price Service from, whether you access the Together Price Service from multiple devices, and other actions you take on the Together Price Service.

We may use information about how you use and connect to the Together Price Service to present the Together Price Service to you on your device.

The processing is necessary for our legitimate interests, namely to tailor the Together Price Service to the user.

We may use this information to determine products and services that may be of interest to you for marketing purposes.

The processing is necessary for our legitimate interests, namely to inform our direct marketing.

We may use this information to monitor and improve the Together Price Service and business, resolve issues and to inform the development of new products and services.

The processing is necessary for our legitimate interests, namely to monitor and resolve issues with the Together Price Service and to improve the Together Price Service generally.

Log files and information about your device. We also collect information about the computer, tablet, smartphone or other electronic device you use to connect to the Together Price Service. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to the Together Price Service through the device, your mobile network, your IP address and your device’s telephone number (if it has one).

We may use information about how you use and connect to the Together Price Service to present the Together Price Service to you on your device.

The processing is necessary for our legitimate interests, namely to tailor the Together Price Service to the user.

We may use this information to determine products and services that may be of interest to you for marketing purposes. 

The processing is necessary for our legitimate interests, namely to inform our direct marketing.

We may use this information to monitor and improve the Together Price Service and business, resolve issues and to inform the development of new products and services.

The processing is necessary for our legitimate interests, namely to monitor and resolve issues with the Together Price Service and to improve the Together Price Service generally.

 

ANNEX 3 – COOKIES AND SIMILAR TECHNOLOGIES

 

Cookie Name

Type of cookie

When is the cookie set?

How long does the cookie stay on my device?

Purpose of the cookie

Creation_Date

Functional

After you register with the Together Price Service

Indefinitely

This local storage object notes the date on which you registered for an account on the Together Price Service.

TPTutorial

Functional 

After you have seen the tutorial

Indefinitely

This local storage object records the fact that you have watched the tutorial on how to use the Together Price Service so as not to show it to you again the next time you use the Together Price Service.

TPUser

Functional 

After you register with the Together Price Service

Indefinitely

This local storage object stores your user information to avoid your device submitting this information to us each time you use the Together Price Service on your device. 

This allows us to optimise the performance of the Together Price Service and you experience of the Together Price Service.

optimizely_data$$pending_events

Functional

After you register with the Together Price Service

Indefinitely

This local storage object is used to identify you, track your actions, and deliver consistent experiences across page loads. 

TPCampaign

Analytical

After you register with the Together Price Service 

Indefinitely

These local storage object track whether you have registered for the Together Price Service after having been referred to the Together Price Service from a marketing link. It allows us to measure the effectiveness of any advertising campaigns.

TPReferral

Analytical

After you register with the Together Price Service

Indefinitely

TPPixel

Analytical

After you register with the Together Price Service

Indefinitely

RecoveryTP

Functional

After you register with the Together Price Service

Indefinitely

This local storage object allows us to identify you when you use the password recovery functionality of the Together Price Service in order to prevent fraudulent password reset requests.

CustomSent

Functional

After you send a sharing request to a custom sharing post

Indefinitely

This local storage object tracks whether you have registered for the Together Price Service after having been invited to join a group on the Together Price Service.

G_ENABLED_IDPS

Functional

On first visiting www.togetherprice.com

2,914,962 days

This cookie is used to authorise you when you log in to the Together Price Service through your Google account.

OCAK

Functional

On first visiting www.togetherprice.com

Until you navigate away from the Together Price Service.

These cookies are stored on your device in order to enable you to remain connected to your Google account when you visit its service again. 

While you are logged in and use plug-ins from other websites, such as ours, Google uses these cookies to improve your user experience.

LSOLH

Functional

On first visiting www.togetherprice.com

358 days

ACCOUNT_CHOOSER

Functional

On first visiting www.togetherprice.com

727 days

LSID

Functional

On first visiting www.togetherprice.com

727 days

GAPS

Functional

On first visiting www.togetherprice.com

730 days

_scid

Targeting

On first visiting www.togetherprice.com

318 days

Sets a unique ID for the visitor, that allows third party advertisers to target the visitor with relevant advertisement. This pairing service is provided by third party advertisement hubs, which facilitates real-time bidding for advertisers.

__stripe_mid

Strictly necessary

On first visiting www.togetherprice.com

365 days

Stripe uses these cookies to remember who you are and process payments without storing any credit card information on our servers.

__stripe_sid

Strictly necessary

On first visiting www.togetherprice.com

Until you navigate away from the Together Price Service.

__utmx

Functional and analytical

On first visiting www.togetherprice.com

558 days

These cookies are used with a tool known as Google Website Optimizer, which helps us improve the Together Price Service. 

They are used to distinguish between two variations of a webpage that might be shown to a visitor, in order to help us determine which version of a page performs better.

__utmxx

Functional and analytical

On first visiting www.togetherprice.com

558 days

datr

Functional

On first visiting www.togetherprice.com

97 days

These cookies are used by Facebook to support social sharing and the integration of Facebook services.

c_user

Functional

On first visiting www.togetherprice.com

90 days

xs

Functional

On first visiting www.togetherprice.com

90 days

sb

Functional

On first visiting www.togetherprice.com

560 days

spin

Functional

On first visiting www.togetherprice.com

Until you navigate away from the Together Price Service.

fr

Functional

On first visiting www.togetherprice.com

90 days

wd

Functional

On first visiting www.togetherprice.com

7 days

dpr

Functional

On first visiting www.togetherprice.com

7 days

presence

Functional

On first visiting www.togetherprice.com

Until you navigate away from the Together Price Service.

localizer-s

Functional

On first visiting www.togetherprice.com

Until you navigate away from the Together Price Service.

We use this cookie to translate and present the Together Price Service in your language.

__cfduid

Functional

On first visiting www.togetherprice.com

1 year

This cookie is used to identify individual clients behind a shared IP address and apply settings on a per-client basis. We use it in connection with ensuring the Together Price Service is presented to you in the correct language, and to identify trusted web traffic and apply security settings on a per-client basis.

PHPSESSID

Strictly necessary

On first visiting www.togetherprice.com

Until you navigate away from the Together Price Service.

This cookie is used to identify you while you visit the Together Price Service in order to provide you with the Together Price Service in accordance with the preferences and information you provide to us when you use the Together Price Service.

AID

Targeting

On first visiting www.togetherprice.com

333 days

This cookie is used by Google to link your activity across devices if you’ve previously signed in to your Google account on another device.

test_cookie

Functional

On first visiting www.togetherprice.com

Until you navigate away from the Together Price Service.

This cookie is used by Google DoubleClick to determine if your browser supports cookies.

__ncuid

Targeting

On first visiting www.togetherprice.com

197 days

These cookies are used by Google DoubleClick to register and report your actions after viewing or clicking one of the advertiser’s ads with the purpose of measuring the efficacy of an ad and to present you with targeted ads.

Please visit https://tools.google.com/dlpage/gaoptout to see how you can opt out of receiving these cookies.  

cto_lwid

Targeting

On first visiting www.togetherprice.com

242 days

DSID

Targeting

On first visiting www.togetherprice.com

13 days

IDE

Targeting

On first visiting www.togetherprice.com

37 days

CONSENT

Targeting

On first visiting www.togetherprice.com

6,912 days

HSID

Targeting

On first visiting www.togetherprice.com

727 days

This cookie is set by Google DoubleClick to collect information about you in order to build a profile of your interests, in order to show relevant ads to you on other websites.

It is also used by third party application providers whose applications are embedded in the Together Price Service (such as Youtube) to keep track of your user preferences and use of such third party applications.

Please visit https://tools.google.com/dlpage/gaoptout to see how you can opt out of receiving these cookies.  

SSID

Targeting

On first visiting www.togetherprice.com

727 days

These cookies collect information about how you use the Together Price Service and any advertising that you may have seen before visiting the Together Price Service.

Please visit https://tools.google.com/dlpage/gaoptout to see how you can opt out of receiving these cookies.  

DV

Targeting

On first visiting www.togetherprice.com

Until you navigate away from the Together Price Service.

1P_JAR

Targeting

On first visiting www.togetherprice.com

30 days

SIDCC

Targeting

On first visiting www.togetherprice.com

90 days

SRCHD

Targeting

On first visiting www.togetherprice.com

141 days

These cookies collect information about how you use the Together Price Service and any advertising that you may have seen before visiting the Together Price Service.

SRCHUID

Targeting

On first visiting www.togetherprice.com

141 days

SRCHUSR

Targeting

On first visiting www.togetherprice.com

141 days

MUID

Targeting

On first visiting www.togetherprice.com

240 days

MUIDB

Targeting

On first visiting www.togetherprice.com

215 days

APISID

Targeting

On first visiting www.togetherprice.com

727 days

These cookies are generally set through the Together Price Service by advertising partners, and used by them to build a profile of your interests and to show you relevant ads on other sites. 

These cookies work by uniquely identifying your browser and device. 

They also allow third party applications embedded in the Together Price Service (such as Youtube) to keep track of your user preferences and use of such third party applications.

Please visit https://tools.google.com/dlpage/gaoptout to see how you can opt out of receiving these cookies.  

SAPISID

Targeting

On first visiting www.togetherprice.com

727 days

NID

Targeting

On first visiting www.togetherprice.com

183 days

SID

Strictly necessary 

On first visiting www.togetherprice.com

728 days

This is a security cookie used to authenticate users, prevent fraudulent use of login credentials, and protect user data from unauthorised parties.

The ‘SID’ and ‘HSID’ cookies contain digitally signed and encrypted records of your Google account ID and most recent sign-in time. The combination of these two cookies allows us to block many types of attack, such as attempts to steal the content of forms that you complete on web pages.

_ga

Analytical / performance

On first visiting www.togetherprice.com

2 years

These cookies are associated with Google Universal Analytics. They are used to calculate visitor, session and campaign data in order to generate reports and information about how the visitor uses the Together Price Service.

They are also used by third party analytics platforms, such as Heap and Hotjar, for similar purposes.

Please visit https://tools.google.com/dlpage/gaoptout to see how you can opt out of receiving these cookies.  

_gid

Analytical / performance

On first visiting www.togetherprice.com

24 hours

_gcl_au

Analytical and targeting

On first visiting www.togetherprice.com

18 days

This cookie is used by HotJar to monitor visitor use of the Together Price Service in connection with reviewing advertising efficiency across websites.

You can opt out of HotJar cookies at https://www.hotjar.com/legal/compliance/opt-out

_hjIncludedInSample

Analytical and targeting

On first visiting www.togetherprice.com

365 days

We use Hotjar cookies to see where visitors look and click on our website. The various Hotjar cookies serve among other things to let Hotjar know whether a visitor is included in the sample or test, and whether to follow a visitor across multiple pages. 

You can opt out of HotJar cookies at https://www.hotjar.com/legal/compliance/opt-out 

_hjRecordingEnabled

Analytical

On first visiting www.togetherprice.com

Until you navigate away from the Together Price Service.

ajs_user_id

Targeting

On first visiting www.togetherprice.com

303 days

ajs_group_id

Targeting

On first visiting www.togetherprice.com

303 days

ajs_anonymous_id

Functional and analytical

On first visiting www.togetherprice.com

293 days

mp_6d7c50ad560e01715a871a117a2fbd90_mixpanel

Performance and analytical

On first visiting www.togetherprice.com

303 days

mp_34b2c3939599013bd0c86fabf1ed8c70_mixpanel

Performance and analytical

On first visiting www.togetherprice.com

303 days

intercom-id-c5ke8zbr

Performance and analytical

On first visiting www.togetherprice.com

208 days

_hp2_id.988570432

Analytical

On first visiting www.togetherprice.com

2 years

We use Heap Analytics cookies to monitor how users use the Together Price Service and to maintain properties related to your browsing of the Together Price Service (such as whether or not you are logged in to the Together Price Service).

_hp2_id.236035469

Analytical

On first visiting www.togetherprice.com

2 years

_hp2_props.236035469

Functional and analytical

On first visiting www.togetherprice.com

2 years

_hp2_ses_props.236035469

Analytical

On first visiting www.togetherprice.com

30 minutes

_attribution_referrer

Analytical

On first visiting www.togetherprice.com

365 days

_attribution_landing_page

Analytical

On first visiting www.togetherprice.com

365 days

_cmpQcif3pcsupported

Strictly necessary

On first visiting www.togetherprice.com

Until you navigate away from the Together Price Service.

This cookie monitors whether you have consented to receive cookies on your device.

_mkto_trk

Performance / analytical

On first visiting www.togetherprice.com

730 days

This cookie links your behaviour on the Together Price Service to the email marketing you receive, in order to measure campaign effectiveness.

eupubconsent

Functional

On first visiting www.togetherprice.com

390 days

These cookies record whether you have provided consent to receive electronic marketing messages.

euconsent

Functional

On first visiting www.togetherprice.com

390 days

raygun4js-userid

Performance / analytical

On first visiting www.togetherprice.com

31 days

These cookies are used to monitor for errors on the Together Price Service.

_csrf

Functional

On first visiting www.togetherprice.com

Until you navigate away from the Together Price Service.

This cookie is used to monitor for Cross Site Request Forgery (“CSRF“). This cookie helps verify that any requests submitted by a device to the Together Price Service come from you rather than an attacker pretending to be you.

VISITOR_INFO1_LIVE

Functional

On first visiting www.togetherprice.com

163 days

These cookies are used by Youtube to keep track of user preferences and views of any Youtube videos embedded in the Together Price Service. They also detect whether you are using the new or old version of the Youtube interface.

LOGIN_INFO

Functional

On first visiting www.togetherprice.com

335 days

YSC

Functional

On first visiting www.togetherprice.com

Until you navigate away from the Together Price Service.

PREF

Functional

On first visiting www.togetherprice.com

730 days

OGPC

Functional

On first visiting www.togetherprice.com

47 days

This cookie enables Google Maps functionality on the Together Price Service.