Three Square Market
This document explains how we use your personal data.
Thank you for choosing to shop with Three Market Square.
We are committed to ensuring the privacy of all users of our market kiosks. Here, we will explain how we hold, process and retain the information that we collect about you.
1. How we use your personal data
1.1. This section provides you with information about:
a) what personal data we hold and process;
b) in respect of personal data that we did not collect from you directly, where we obtained that data from, and what types of data we have collected;
c) the purposes for which we may process your personal data; and
d) the legal grounds on which we process your data.
Customers of Three Market Square Mini-Markets
1.2. As a customer using our markets and kiosks, you may either choose to shop with us in one of two ways. You may choose to set up an account with us, make a lump-sum prepayment using your credit or debit card, and draw down from this sum each time you shop with us. Alternatively, you do not have to set up an account with us and can simply pay each time you shop with us.
1.3. Account data. If you choose to set up an account with us, we may process information about you that you provide to us ("account data"). This account data may include your name, address, telephone number, email address, user name and password, your product purchases, and how much you have spent with us each month.
This account data may be processed each time you shop with us. We may process this information for the purposes of creating your account, administering your account and purchases, and for sending you receipts for your purchases by email. Please note that we do not collect or hold or have access to payment details such as your debit or credit card number, bank account number or sort code.
The legal basis for this processing is for the purposes of performing our contract with you, or in taking steps at your request prior to entering into a contract.
1.4. Purchase Data. If you do not have an account with us and are simply making a one-off purchase, we will not collect any of your personal data.
1.5. Special categories of data. When you create an account with us, you can choose whether or not you want to activate the digital fingerprint payment / login process. If you do want to use this function, you will need to provide us with certain biometric data around the impression of your fingerprint.
It’s only a mathematical representation of your fingerprint that is stored—never images of your finger itself. We use this data to allow you to login securely instead of entering your user id and password in order to process your purchases. Using the fingerprint payment process is optional, and as such the legal basis for any processing of your biometric data in this way is consent.
Our business clients
1.6. Point of contact data. If you are employed by one of our corporate clients such as our operators, which has a contractual arrangement with Three Square Market for the provision of services (the “main contractor”), we may use your information such as your name, email address, telephone number and employment details (the “point of contact data”) to enable us to:
a) provide services to you in accordance with the contract that we have with the main contractor;
b) communicate with you regarding the provision of such services;
c) improve the services that we provide and to ensure that we maintain our levels of client care; and
d) marketing our products, services, promotions and offers to the main contractor.
We will treat the main contractor as the controller of any point of contact data that we are provided with. We may receive personal data in respect of such points of contact direct from the main contractor.
We will process any such personal data referred to in this paragraph 1.6 strictly in accordance with the instructions of the main contractor, not the individual point of contact, including sharing all such data with the main contractor.
The legal basis for this processing is our legitimate interests in supplying products or services to the main contractor, in managing and administering our relationship and contract with the main contractor, and in marketing our products and services to the main contractor.
Other processing that we may carry out
1.7. Website data. We may process data about your use of our website and services ("website data"). The website data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the website data is our analytics tracking system. This website data may be processed for the purposes of analysing the use of the website and services.
The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
1.8. Enquiry data. We may process information contained in any enquiry you submit to us regarding our products or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you.
The legal basis for this processing is our legitimate interests, namely dealing with and responding to your enquiry appropriately.
1.9. Correspondence data. We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping.
The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
1.10. Other processing activities. In addition to the specific purposes for which we may process your personal data set out above, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2. Providing your personal data to others
2.1. To our operators. We work closely with our operators, who own the stores in which our markets and kiosks are situated. Kiosk operators can access your account data in order to administer your account and monitor the use of their markets and kiosks for statistical purposes. The legal basis on which we rely to allow our operators access to your account data is our legitimate interests in allowing the operators to ensure the efficient running and administering of their market and kiosks. We have appropriate contracts and security safeguards in place with all of our operators to ensure the security of your data. Your personal data is never sent to any third parties.
2.2. Our insurers/professional advisers. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.
2.3. Transfer of use data. Where we provide your personal data to any third party. Where we share your personal data with any third party, we will ensure this processing is protected by appropriate safeguards including a suitable data processing agreement with that third party.
2.4. Main contractors. We may share personal data with main contractors as set out in paragraph 1.6 above.
2.5. To comply with legal obligations. In addition to the specific disclosures of personal data detailed above, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation we have to comply with, or in order to protect your vital interests or the vital interests of another individual. This may include disclosing your personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
3. Transfers of your personal data outside of the European Economic Area
We are of course situated in the United States of America. As such, your account data and biometric data will be transferred outside of the EEA and stored on our secure servers provided by Amazon Web Services and situated in the United States of America. In all cases, transfers outside of the EEA will be protected by appropriate safeguards and contracts.
4. Retaining and deleting personal data
4.1. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
4.2. Unless we contact you and obtain your consent for us to retain your personal data for a longer period, we will retain and delete your personal data as follows:
a) Account data (including special categories of personal data) in respect to a particular account will be anonymised if we find that there has been no activity on that account for 6 consecutive months or more. We will only retain anonymous data in respect to transactions carried out on that account for administrative purposes for 7 years from the date that the account was deactivated and anonymised.
b) Point of Contact data will be retained for the duration of the contract that we have with the main contractor and for such period after termination of the contract, or as specified in that contract or agreed between Three Square Market and the main contractor.
c) Website data will be retained for 12 months following the date of our last contact or dealing with you, at the end of which period it will be deleted from our systems.
d) Enquiry data will be retained for 12 months following the date of our last contact or dealing with you, at the end of which period it will be deleted from our systems.
e) Correspondence data will be retained for 12 months following the date of our last contact or dealing with you, at the end of which period it will be deleted from our systems.
4.3. We may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
5.1. We may update this policy from time to time by publishing a new version on our website.
5.2. You should check this page occasionally to ensure you are happy with any changes to this policy.
5.3. We may notify you of changes to this policy by email.
6. Your rights
6.1. You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
a) your request not being found to be unfounded or excessive, in which case a charge may apply; and
b) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
6.2. We may withhold personal information that you request to the extent permitted by law.
6.3. You may instruct us at any time not to process your personal information for marketing purposes.
6.4. In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
6.5. Your right to access your data. You have the right to ask us to confirm whether or not we process your personal data and, to have access to the personal data, and any additional information. That additional information includes the purposes for which we process your data, the categories of personal data we hold and the recipients of that personal data. You may request a copy of your personal data. The first copy will be provided free of charge, but we may charge a reasonable fee for additional copies.
6.6. Your right to rectification. If we hold any inaccurate personal data about you, you have the right to have these inaccuracies rectified. Where necessary for the purposes of the processing, you also have the right to have any incomplete personal data about you completed.
6.7. Your right to erasure. In certain circumstances you have the right to have personal data that we hold about you erased. This will be done without undue delay. These circumstances include the following: it is no longer necessary for us to hold those personal data in relation to the purposes for which they were originally collected or otherwise processed; you withdraw your consent to any processing which requires consent; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are certain general exclusions of the right to erasure, including where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for establishing, exercising or defending legal claims.
6.8. Your right to restrict processing. In certain circumstances you have the right for the processing of your personal data to be restricted. This is the case where: you do not think that the personal data we hold about you is accurate; your data is being processed unlawfully, but you do not want your data to be erased; it is no longer necessary for us to hold your personal data for the purposes of our processing, but you still require that personal data in relation to a legal claim; and you have objected to processing, and are waiting for that objection to be verified. Where processing has been restricted for one of these reasons, we may continue to store your personal data. However, we will only process it for other reasons: with your consent; in relation to a legal claim; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
6.9. Your right to object to processing. You can object to us processing your personal data on grounds relating to your particular situation, but only as far as our legal basis for the processing is that it is necessary for: the performance of a task carried out in the public interest, or in the exercise of any official authority vested in us; or the purposes of our legitimate interests or those of a third party. If you make an objection, we will stop processing your personal information unless we are able to: demonstrate compelling legitimate grounds for the processing, and that these legitimate grounds override your interests, rights and freedoms; or the processing is in relation to a legal claim.
6.10. Your right to object to direct marketing. You can object to us processing your personal data for direct marketing purposes. If you make an objection, we will stop processing your personal data for this purpose.
6.11. Your right to data portability. Where you have given us consent to process your personal data, or where we are processing your personal data for the performance of a contract, you have a legal right to receive a copy of the personal data we hold about you in a structured, commonly used and machine readable format. When a data request is made of us we will make available all applicable personal data to you in .csv format to be passed to the appropriate third party on your instruction. We will not however process your data in this way if we believe that it may pose a threat to the security of the data.
6.12. Your right to object for statistical purposes. You can object to us processing your personal data for statistical purposes on grounds relating to your particular situation, unless the processing is necessary for performing a task carried out for reasons of public interest.
6.13. Automated data processing. To the extent that the legal basis we are relying on for processing your personal data is consent, and where the processing is automated, you are entitled to receive your personal data from us in a structured, commonly used and machine-readable format. However, you may not have this right if it would adversely affect the rights and freedoms of others.
6.14. Complaining to a supervisory authority. If you think that our processing of your personal data infringes data protection laws, you can lodge a complaint with a supervisory authority responsible for data protection. You may do this in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
6.15. Right to withdraw consent. To the extent that the legal basis we are relying on for processing your personal data is consent, you are entitled to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
6.16. Exercising your rights. You may exercise any of your rights in relation to your personal data by written notice to us in addition to the other methods specified above.
6.17. Point of Contact Data. PARAGRAPHS 6.1 – 6.16 SHALL NOT APPLY TO POINT OF CONTACT DATA OBTAINED OR PROCESSED BY THREE SQUARE MARKET IN RESPECT OF POINTS OF CONTACT IN CONNECTION WITH A MAIN CONTRACTOR. IN RESPECT OF SUCH DATA:
A. THREE SQUARE MARKET IS ACTING AS A PROCESSOR OF THAT DATA AND THE MAIN CONTRACTOR IS THE CONTROLLER;
B. POINTS OF CONTACT SHOULD CONTRACT THE MAIN CONTRACTOR TO EXERCISE THE RIGHTS SET OUT IN THIS PARAGRAPH 6.
7. IP Addresses and Cookies. Cookies are very small text files that are stored on your computer when you visit some websites.
8. Our details
8.1. This software is owned and operated by Three Square Market Limited.
8.2. We are registered in England and Wales under registration number 11149434, and our registered office is at 2nd Floor Hygeia House, 66 College Road, Harrow, Middlesex, England, HA1 1BE.
8.3. You can contact us:
a) by post, using the postal address given above;
b) using our website contact form;
c) by telephone, on the contact number published on our website from time to time; or
d) by email, using the email address published on our website from time to time.
9. Data protection officer
Our data protection officer's contact details are: Rick Leib, who can be contacted via email: RickL@tkc32m.com, or telephone: 715.629.9770.