Privacy Notice | Truth Trolley

Truth Trolley Privacy Policy

1. IMPORTANT INFORMATION AND WHO WE ARE

Privacy notice

This privacy notice sets out how the controller, PERSONIFI LTD (collectively referred to as “Truth Trolley”, “we”, “us” and “our”), Processes Personal Data. This privacy notice is addressed to individuals outside our organisation with whom we interact, including customers, visitors to our website, users of our platform and/or other products and services, personnel of corporate customers and vendors and applicants for employment (together, “you”)).

This notice may be amended or updated from time to time to reflect changes in our practices with respect to the Process of Personal Data. This notice is not intended for children and we do not knowingly collect Personal Data relating to children.

If you have any questions about this privacy notice, including any requests to exercise your legal rights (paragraph 10), please contact us using the information set out in the contact details section (paragraph 12).

2. THE TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU

Personal Data means any information about an individual from which that person can be identified.

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

Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and age-range and gender.
Demographic Data includes geographic region, household size, household income range, language preferences.
Contact Data includes billing address, email address and telephone numbers, as well as any records of correspondence if you contact us.
Shopping Transaction Data includes payment transaction details and receipts itemising purchases.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Profile Data includes your username and password, your preferences, feedback and survey responses, to the extent applicable.
Usage Data includes information about how you interact with and use our website, products and services.
Grocery Data includes information about your shopping purchases and preferences and any other information contained within customer loyalty cards, grocery and food shopping locations of preference and frequency of shopping trips.
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
Consent records includes records of any consents you have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).
Professional details include your CV, professional history, qualification details and information about your experience, and language abilities.
Views and opinions include any views and opinions that you choose to send to us, or publicly post about us on social media platforms.

We also collect, use and share aggregated data such as statistical or demographic data which is not Personal Data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect Personal Data about you from the following sources:

Data provided to us. You may give us your Personal Data by filling in online forms on our website, or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:

sign up to our platform or create an account on our website;
upload any data to our systems (e.g., your grocery loyalty cards or receipts);
subscribe to any newsletters or request marketing to be sent to you;
give us feedback or contact us, whether online or in-person; or
submit a job application.

Relationship data. We collect or obtain Personal Data in the ordinary course of our relationship with you (e.g., we provide a service to you, or to your employer).
Data we obtain in person. We may also obtain Personal Data during meetings, at trade shows or any other events we attend.
Third parties. In certain circumstances, we may collect or obtain Personal Data from third parties who provide it to us (e.g., pre-employment screening checks for job applicants).

4. HOW WE USE YOUR PERSONAL DATA

Legal basis

The law requires us to have a legal basis for collecting and using your Personal Data. We rely on one or more of the following legal bases:

Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
Legitimate interests: We may use your Personal Data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Legal obligation: We may use your Personal Data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
Consent: We rely on your valid consent only where we have obtained your active agreement to use your Personal Data and/or your Sensitive Personal Data for a specified purpose, for example to Process the Grocery Data and Demographic Data that you upload to our platform.
Establishment, exercise or defence of legal claims: We may Process your Personal Data, including any Sensitive Personal Data (where applicable), where the Processing is necessary for the establishment, exercise or defence of legal claims.

5. 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 the various categories of 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.

Purpose/Use

The provision of our website (including registering you as a new customer, providing content to you, troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type of data

(a) Identity

(b) Contact

(d) Consent records

Legal basis

We have a legitimate interest in carrying out the Processing for the purpose of providing our website for your use and maintaining our website’s functionality and network security.

We have validly obtained your prior consent to the Processing.

Managing our relationship with you which will include:

(a) Notifying you about changes to our terms or Privacy Notice

(b) Dealing with your requests, complaints and queries

(a) Identity

(b) Contact

(d) Marketing and Communications

We have a legitimate interest in carrying out the Processing for the purpose of managing our relationship with you and keeping our records updated.

The Processing is necessary to comply with a legal obligation.

Operating our business, including our platform and/or any other goods or services offered website

(a) Identity

(b) Contact

(d) Grocery

(e) Demographic

(f) Transaction

We have legitimate interests in running our business, carrying out administration and IT services, providing a prescribed service to our customers.

We have validly obtained your prior consent to the Processing.

To use data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing

(a) Contact

(b) Usage

We have legitimate interests to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy.

To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you based on your Profile Data.

(a) Identity

(b) Contact

(d) Profile

(e) Marketing and communications

We have validly obtained your prior consent to receiving direct marketing communications.

Establishment, exercise and defence of legal claims, including the management of any regulatory or legal claim, establishment of facts and claims, exercise and defence of legal rights and claims.

Each category of Personal Data, to the extent necessary in the context of the relevant legal obligation or regulatory requirements or guidance.

The Processing is necessary for the establishment, exercise or defence of legal claims.

Recruitment and job applications, including advertising positions, conducting interviews, analysing the suitability for the relevant position, records of hiring decisions and offer and acceptance details.

Identity
Contact
Professional Details
Views and opinions
Demographic
Consent records

The Processing is necessary for compliance with a legal obligation (especially in respect of applicable employment law).

We have a legitimate interest in carrying out Processing for the purpose of recruitment activities and handling job applications.

We have validly obtained your prior consent to the Processing (e.g., where this is necessary for the purposes of criminal records checks).

6. DISCLOSURES OF YOUR PERSONAL DATA

We may share your Personal Data where necessary with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

Third-party processors (e.g., payment service providers, including Wix Payments and PayPal).
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 notice.

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.

7. INTERNATIONAL TRANSFERS

We do not currently transfer your Personal Data outside of the UK.

8. 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.

9. 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.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for [six] years after they cease being customers.

In some circumstances you can ask us to delete your data: see Paragraph 10 below for further information.

As mentioned above, in some circumstances we will de-identify or anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may retain and use this information indefinitely without further notice to you.

10. YOUR LEGAL RIGHTS

You have a number of rights under data protection laws such as the UK GDPR and the Data Protection Act 2018 in relation to your Personal Data.

You have the right to:

Request access to your Personal Data (commonly known as a "subject access request"). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully Processing it.
Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your Personal Data in certain circumstances. 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.
You also have the absolute right to object any time to the Processing of your Personal Data for direct marketing purposes, where applicable (see OPTING OUT OF MARKETING in paragraph 5 for details of how to object to receiving direct marketing communications).
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 (see the table in paragraph 5 for details of when we rely on your consent as the legal basis for using your 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.
Request restriction of Processing of your Personal Data. This enables you to ask us to suspend the Processing of your Personal Data in one of 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; or
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- In addition, you have the right to object to Processing of your Personal Data where we are relying on a legitimate interest as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.

If you wish to exercise any of the rights set out above, please contact us (see contact details set out in Paragraph 12).

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.

11. CONTACT DETAILS

If you have any questions about this privacy notice or about the use of your Personal Data or you want to exercise your privacy rights, please contact us in the following ways:

Email address: info@personifidata.com
Postal address: 3rd Floor, 86-90 Paul Street, London, England, EC2A 4NE United Kingdom
Telephone number: 07801 419227

12. COMPLAINTS

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.

13. CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy notice under regular review. This version was last updated on 19th January 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, for example a new address or email address.

14. THIRD-PARTY LINKS

This website 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 notice of every website you visit.

15 DEFINITIONS

"Controller" means the entity that decides how and why Personal Data are Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.

"UK GDPR” means the General Data Protection Regulation (EU) 2016/679 as forms part of the laws applicable in the UK by virtue of section 3 of the European Union (Withdrawal) Act 2018 and the Data Protection Act 2018, and as applied and modified by Schedule 2 of the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019 or as modified from time to time.

"Personal Data” means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

"Process”, “Processing” or “Processed” means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

"Sensitive Personal Data” means Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, biometric data, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that are deemed to be sensitive under applicable law.

Aggregating and/or anonymising Personal Data so that it will no longer be considered Personal Data

Identity Data
Contact Data
Profile Data

We have legitimate interests in Processing this Personal Data, such as to generate other data for our use, or share data with third parties, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.

Direct marketing

During the registration process on our website when your Personal Data is collected, you may be asked to indicate your preferences for receiving direct marketing communications from us via email or SMS.

We may also analyse your Identity, Contact, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Third-party marketing

We will get your express consent before we share your Personal Data with any third-party for their own direct marketing purposes. For the avoidance of doubt, we do not currently share any of your Personal Data with third-parties for their own direct marketing purposes.

Opting out of marketing

You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us. If you opt-out of receiving marketing communications, you may still receive service-related communications that are essential for administrative or customer service purposes.