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Privacy Policy

Privacy Policy

Effective Date: 1st September 2025

Last Updated: 1st September 2025

Indulgepass Limited ("Indulgepass," "we," "us," or "our") values your privacy. This Privacy Policy explains how we collect, use, share, and protect your personal data when you use the Indulgepass app, website, and related services (the "Platform").

We process your personal data in accordance with the General Data Protection Regulation (GDPR), the UK GDPR, and other applicable privacy laws.

1. Data We Collect

We may collect the following categories of personal data:

  • Account Information: Name, email address, phone number, password.
  • Profile Details: Preferences and demographic details (optional).
  • Payment Data: If you subscribe or purchase services, we process payment details via secure third-party payment providers.
  • Usage Data: Interactions with the Platform, offers viewed or redeemed, device identifiers, IP address, browser type, and app activity logs.
  • Location Data: If you enable location services, we may collect your approximate location to show nearby offers.
  • Communications: Messages, support requests, survey responses, or feedback provided to us.

2. How We Use Your Data

We use your personal data to:

  • Provide, personalize, and improve the Platform.
  • Enable you to view and redeem offers from participating vendors.
  • Process payments and manage subscriptions.
  • Communicate with you about your account, updates, and promotions (with your consent where required).
  • Ensure security, prevent fraud, and comply with legal obligations.
  • Analyze trends and improve our services.

3. Legal Bases for Processing (GDPR)

We process your personal data under the following legal bases:

  • Contract: To provide the Platform and fulfill our agreement with you.
  • Consent: For marketing communications and optional features (you may withdraw consent at any time).
  • Legal Obligation: To comply with financial, tax, or regulatory requirements.
  • Legitimate Interests: To improve our services, prevent misuse, and protect our rights.

4. How We Share Your Data

We may share your data with:

  • Vendors: Limited information necessary to redeem an offer (e.g., confirmation that you are an active user).
  • Service Providers: Trusted third parties that host data, process payments, or provide analytics.
  • Legal Authorities: When required to comply with laws or respond to lawful requests.
  • Business Transfers: In the event of a merger, acquisition, or sale of assets.

We do not sell your personal data.

5. International Data Transfers

If your data is transferred outside the European Economic Area (EEA) or UK, we ensure adequate safeguards are in place, such as Standard Contractual Clauses or other lawful mechanisms.

6. Data Retention

We retain personal data only as long as necessary for the purposes outlined in this Policy, unless a longer retention period is required by law. When data is no longer needed, it is securely deleted or anonymized.

7. Your Rights (GDPR/UK GDPR)

You have the following rights regarding your personal data:

  • Access – Request a copy of your data.
  • Rectification – Correct inaccurate or incomplete data.
  • Erasure – Request deletion of your data ("right to be forgotten").
  • Restriction – Limit processing of your data.
  • Portability – Request transfer of your data to another service.
  • Objection – Object to processing based on legitimate interests or direct marketing.
  • Withdraw Consent – Withdraw consent at any time (e.g., unsubscribe from marketing).

To exercise these rights, contact us at: support@indulgepass.co.uk.

8. Security

We use appropriate technical and organizational measures to protect your data against unauthorized access, loss, or misuse. However, no system is 100% secure, and we cannot guarantee absolute security.

9. Children's Privacy

The Platform is not intended for children under 16. We do not knowingly collect personal data from minors without parental consent.

10. Changes to This Policy

We may update this Privacy Policy from time to time. Updates will be posted on the Platform with a new effective date.

11. Contact Us

For questions or to exercise your privacy rights, contact us at:

Indulgepass Limited
Email: support@indulgepass.co.uk
Address: Barnfield Business Centre, Brunswick Street, Nelson, Lancashire, BB9 0HT, United Kingdom

If you are in the EEA/UK, you also have the right to lodge a complaint with your local data protection authority.