Privacy Notice

Last updated: 16 July 2020

Version: 2.0

1.1 We recommend that you read this Privacy Notice in full to ensure you are fully informed. However, if you only want to access a particular section of this Privacy Notice, then you can click on the relevant link below to jump to that section.

2. What is this Privacy Notice about?

2.1 dunnhumby Limited (referred to in the Privacy Notice as “we”, “our” or “us”) respects your right to privacy. This Privacy Notice explains who we are, how we collect, share and use personal data about you (referred to in the Privacy Notice as “data”), as a member of Shopper Thoughts, and how you can exercise your privacy rights in relation to your participation in the Shopper Thoughts community.

2.2 This Privacy Notice applies to data that we collect via our website at https://shopperthoughts.com, and Shopper Thoughts-related applications including our mobile application (also referred to as the “app”) (collectively “Shopper Thoughts”).

2.3 If you have any questions or concerns about our use of your data, then please contact us using the contact details provided at section 14 of this Privacy Notice (“How to contact us”).

3. What does dunnhumby do?

3.1 dunnhumby is a consumer data science company, headquartered in the U.K. but with group companies all around the world. Our products and services help retailers and brands analyse data in order to improve consumer experiences and build loyalty.

3.2 For more information about dunnhumby, please see the “About Us” section of our website at https://www.dunnhumby.com/about-us.

4. What is Shopper Thoughts?

4.1 Shopper Thoughts is a community for consumers to share experiences and thoughts on shopping via our website, mobile application, discussion boards, prize draws and surveys. This helps retailers and brands to develop products and improve the shopping experience for their customers. Members benefit from participation by obtaining “Shopper Thoughts points" that can be redeemed for points and shopping vouchers of high-street and online retailers (for example, Tesco Clubcard points and Amazon vouchers).

5. What data do we collect?

5.1 If you are a member of Shopper Thoughts, we may collect the following data about you:

Data that you provide voluntarily

5.2 Voluntarily provided data is data that you provide when you register as a member of Shopper Thoughts and through your use of Shopper Thoughts. This data includes the following:

(a) Survey data – your responses and results of our online surveys which may relate to things such as personality, values, attitudes, interests, and health and lifestyle. Survey data includes, for example, your diet and exercise preferences, your media consumption preferences, your attitudes on sustainability, your responses to questions as to whether you agree or disagree with certain value statements or behaviours (e.g. a healthy diet is part of my life);

(b) Member data – data which consists of:

i. Contact details – name, street address, post code, email address, username, home telephone number, mobile telephone number;

ii. Demographic data – age, gender, date of birth, photo, region, household income, family composition (e.g. number and gender of children, if any);

(c) Tesco Clubcard data – Clubcard number and details of products and services you have purchased which are linked to that Tesco Clubcard account;

(d) Contribution data - any ideas, suggestions or comments you post on Shopper Thoughts (“contributions”);

(e) Videos or photos you upload to Shopper Thoughts (e.g. in response to a survey question or as part of a contribution) or taken of you with your consent when you attend a focus group session;

(g) Occasionally, we may ask you questions about your health. If we do, we will inform you at the time we collect this data and ask you to consent to us processing it. If we do not ask you for data about your health please ensure you do not provide it.

If you provide data that relates to your health or other special category data such as your ethnicity, religion or political beliefs, we will treat your voluntary provision of such data as your consent to our use of such data for the purposes specified in this Privacy Notice.

When you provide data that could potentially be used to reveal information about your health or other special category data such as your ethnicity, religion or political beliefs, it is not our intention to use that data to reveal health or other special category data and we will not do so; and

(h) In Malaysia, we also ask you to indicate your ethnicity and language on a purely voluntary basis. Please do not provide ethnicity and language data if we do not ask for it.

Data that we collect automatically

5.3 When you use Shopper Thoughts, we may collect certain data automatically from your device – this might be your desktop, laptop, tablet, or mobile phone. In some countries, including countries in the European Economic Area, this data may be regulated under applicable data protection and privacy laws. Specifically, the data we collect automatically from your device may include:

(a) your IP address and broad geographic location (e.g. country or city-level location);

(b) device type;

(c) unique device identification numbers;

(d) browser-type;

(e) operating system and other technical information;

(f) data about how your device has interacted with Shopper Thoughts, including the pages accessed and links clicked as well as details of how you arrived at Shopper Thoughts; and

(g) if you use the Shopper Thoughts app in the UK and Republic of Ireland, we also collect granular geographic location data (e.g. street level location) if you have consented to this.

5.4 Some of the data that we collect automatically is collected using cookies and similar tracking technology. For further information about the types of cookies we use, why, and how you can control cookies, please see our Cookie Notice.

Data that we obtain from third party sources

5.5 From time to time, we may receive data about you from third party sources including our clients (including but not limited to Tesco, retailers, media clients and fast-moving consumer goods clients), public databases and data aggregators. Before obtaining this data we first check that these third parties either have your consent or are otherwise legally permitted to disclose your data to us. Examples of the kinds of data that we may obtain from third parties include:

(a) your demographic data (including but not limited to your region and affluence based on an analysis of data relating to your household income, level of education and chief income earner within your household) from Tesco Clubcard;

(b) shopping data, online user activity, preferences and information about your lifestyle (for example, your hobbies and interests); and

(c) publicly available data such as user-generated content, blogs and postings.

6. How we use your data and our legal bases

6.1 We process data that you provide voluntarily (for example, survey data) and some other data that we collect or receive from third parties (for example, shopping data) to create “insight data” for our retail or brand clients to enable them to improve customer experiences and build loyalty among their customers. Our processing of data for this purpose is necessary to pursue our legitimate interest to provide data insight services to our clients.

In particular, we match your survey data to your shopping data (such as shopping behaviour in Tesco stores and Tesco online) to learn about or predict your behaviour, habits or preferences as a consumer of our clients’ products (for example, we use data science to understand which types of consumers are more likely to buy a specific product, or whether there are correlations between consumers who buy a product and consumers who buy a different product).

We have described when we share data, including insight data, with clients at section 7 of this Privacy Notice. We may share insight data with our clients in an aggregated, anonymised, pseudonymised or identifiable format. You can learn more about this at section 8 of this Privacy Notice.

6.2 We process the data you provide to us voluntarily to do the following things, which enable you to use Shopper Thoughts:

(a) to register you as a Shopper Thoughts participant and select you for surveys that you are most likely to enjoy;

(b) to respond to your queries or comments and provide Shopper Thoughts community support;

(c) to facilitate your redemption of Shopper Thoughts points and consequent delivery of rewards and incentives;

(d) to personalise your experience of using Shopper Thoughts (e.g. profile photo).

Our use of your data for purposes (a) to (c) above is necessary for the performance of our contract with you (or before entering into a contract with you if you have expressed an interest in Shopper Thoughts).

We process your data for purpose (d) above to pursue our legitimate interest to make your Shopper Thoughts experience enjoyable and make our Shopper Thoughts platform user-friendly.

6.3 We also process the data you provide to us voluntarily to do the things listed below, which are necessary for our legitimate interests to make your experience of Shopper Thoughts user friendly, to develop our business, and to improve the Shopper Thoughts product:

(a) better understand what products or services may be of interest to you;

(b) send you products or samples as part of a Shopper Thoughts survey, or help our clients to do so;

(c) analyse the effectiveness of Shopper Thoughts surveys; and

(d) test and improve the mathematics, science and processes we use in our other dunnhumby group businesses and those we use in the course of providing data insight services to our clients, for example to group individuals by their common characteristics (sometimes referred to as the “segmentation” of groups of people) and predict people’s shopping behaviour.

6.4 We process the data automatically collected about you (except granular geographic data) to:

(a) technically provide Shopper Thoughts to you. This data processing is necessary for us to perform our contract with you. It may also be necessary for compliance with certain legal obligations such as ensuring the security of your data in our systems;

(b) better understand how you use Shopper Thoughts;

(c) better understand what content on Shopper Thoughts is of interest to you (e.g. the types of Shopper Thoughts activities you interact with most, incentives you would prefer); and

(d) for our internal analytics purposes and to improve the quality and relevance of Shopper Thoughts to you. We use cookie tracking or similar technologies for the same purpose.

We process data for the purposes set out at paragraphs (b) to (d) above to pursue our legitimate interests to improve our Shopper Thoughts platform, surveys and related services to our clients, and to make your Shopper Thoughts experience (for example, our surveys) relevant to you. Where we use cookies or similar technologies, we will do so in accordance with our Cookie Notice.

6.5 We process granular geographic data (e.g. street level location of a supermarket where you shop) to tailor our survey to your shopping experience and make your Shopper Thoughts experience more engaging for you and useful to us. We do not store granular geographic data but our third-party service provider ResearchBods (as described at section 7(d) of this Notice) collects this type of data on our behalf only if you use the Shopper Thoughts app and have previously consented to the collection of this data via the app. You will be asked to give your consent (or opt in) to the collection of geographic location data when you start using the app. You can withdraw your consent (opt out) from the app settings at any time. We will not use your granular geographic data for any other purpose.

6.6 We use the data we receive from third parties (see section 5.5 above) to maintain and improve the accuracy of the records we hold about you and improve your experience as a member of the Shopper Thoughts community.

6.7 We will only process special category data (e.g. health data, as described in section 5.2(g)) with your consent.

6.8 We may send you marketing communications for dunnhumby products or services via e-mail. You can opt out of receiving marketing e-mails from us at any time. Please see how in section 12.1(c).

6.9 We may display non-targeted advertisements for related dunnhumby products or services to you within the Shopper Thoughts website or app.

6.10 If you have questions about or need further information concerning the legal bases on which we use data about you, please contact us using the contact details provided under the “How to contact us” section below.

7. Who does dunnhumby share my data with?

7.1 We may disclose your data to:

(a) our group companies;

(b) our clients (for example, Tesco) to provide insights as described at section 8 below, and to enable your redemption of Shopper Thoughts points;

(c) our academic research partners (e.g. universities) who we work with to improve our research methodologies (e.g. our survey questions) and develop new insight solutions for our clients;

(d) third party service providers who help us provide Shopper Thoughts, for example by hosting our website and app, enabling certain features or functionality including user tracking, or by providing ancillary services such as support and maintenance of the websites and app, facilitating member rewards, security technology, or helpdesk support to our members. The main third party service providers that we use for Shopper Thoughts are:

i. ResearchBods – the developer of the Shopper Thoughts website and app which provides continued development, technical and market research services to us. They are also the Shopper Thoughts community manager in UK and Ireland. Their data is hosted on AWS based in the London region, and in Ireland;

ii. InsightLabs - the developer of the Shopper Thoughts website which provides continued development, technical and market research services to us. They are our community manager within Central Europe (Czech, Slovakia, Hungary and Poland). Their data is hosted in Czech Republic; and

iii. Borderless Access - the developer of the Shopper Thoughts website which provides continued development, technical and market research services to us. They are our community manager within Asia (Thailand and Malaysia). Their data is hosted on cloud on US-based servers.

Depending on your country, ResearchBods, InsightLabs and Borderless Access will be notified when you have hit 1000 points (or the relevant redemption threshold in your country) and they will make sure that you can redeem your Shopper Thoughts points for Tesco Clubcard points (if relevant in your country) or for an online voucher;

(e) any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary to:

(i) comply with applicable law or regulation;

(ii) exercise, establish or defend our legal rights; or

(iii) protect your vital interests or those of any other person;

(g) any other person with your consent to the disclosure.

8. How does dunnhumby share my data?

8.1 We share your personal data (excluding photos and videos) as follows:

(a) in an aggregated format: we share our analysis of data collected from you along with data collected from other members and remove any individual identifiers. An example of aggregated survey data is ‘18% of customers who said they liked the new product were 25-34 years old’;

(b) in an anonymised format: we share your comments provided in any open text box survey questions or in a contribution on Shopper Thoughts, but we remove any personal identifiers that could be used to identify you. An example of an anonymised comment is ‘I preferred product B but thought product A was better value for money’;

(c) in a pseudonymised format: we sometimes share data you provide linked to an ID that allows our clients to do their own analysis of the survey data we collect across multiple members, or use it to do further analysis of the aggregated data we have provided them. When we do this, we remove any personal identifiers (e.g. location, age or any other data) which could be used to identify you. The recipients will not be able to identify you using this data.

An example of pseudonymised data is:

Pseudonymised ID Q1 Q2 Q3 Q4
9876543210 1 1 Aldi 3

The example above illustrates the response options you selected for the questions in the survey. ‘Aldi’ is an example of text inputted for an open text question;

(d) in an identifiable format:

i. we sometimes share your survey data with our client and parent company, Tesco, at an individual level with a pseudonymous ID (as in (c) above). However, the pseudonymous ID can be used by Tesco to identify you in their Clubcard database so that they can match the data we have collected through Shopper Thoughts to your shopping behaviour in Tesco stores and Tesco online.

ii. Research Bods, Borderless Access and Insight Labs host Shopper Thoughts in their respective territories (as described at section 7.1(d)) above and receive all of the data you provide. Therefore, these service providers will be able to identify you.

8.2 We share your photos and videos as follows:

(a) We share photos and videos that you have voluntarily uploaded to Shopper Thoughts, with the parties listed in section 7 in the format they are provided. You (and anyone else who appears in the film) will be identifiable. We share these photos and videos as necessary for our legitimate interest to provide data insight services to our clients.

(b) Where you have given your consent, we share photos and videos that we have taken of you when you attend a focus group session, with the parties listed in section 7.

9. How does dunnhumby keep my data secure?

9.1 We use appropriate technical and organisational measures to protect the data that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your data. Specific measures we use include restricting access to staff on a need to know basis and sending aggregate data to third parties. We also encrypt your username and email address in transit.

10. International data transfers

10.1 Our servers are located in the EU and the US. However, our group companies and third party service providers and partners operate around the world.

10.2 As a result, your data may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection and privacy laws that are different to the laws of your country and, in some cases, may not be as protective.

10.3 However, we have taken appropriate safeguards to require that your data will remain protected in accordance with this Privacy Notice. These include implementing the European Commission’s Standard Contractual Clauses for transfers of data between our group companies, which require all group companies to protect data they process from the European Economic Area in accordance with European Union data protection and privacy law.

10.4 Our Standard Contractual Clauses can be provided on request. We have implemented similar appropriate safeguards with our third party service providers and partners and further details can be provided upon request.

11. Data retention

11.1 By default, we will keep data collected via Shopper Thoughts (for example, survey data) for a maximum of 6 years from collection. All data older than 6 years will be deleted unless we receive a request from a member or former member to delete their data sooner.

11.2 All member data will be held for 6 years after the member has left the Shopper Thoughts community unless we receive an earlier request from the member for their data to be deleted.

11.3 All data of a member or former member will be deleted within 30 days of receiving a request for their data to be deleted.

11.4 We may need to keep some of your data for longer (even if you have submitted a deletion request) if we have an ongoing legitimate business need or a specific legal obligation to do so (for example, to comply with applicable legal tax or accounting requirements, or to maintain a suppression list of former members who no longer wish to participate or be contacted). When we have no ongoing legitimate business need to process your data, we will either delete or anonymise the data or, if this is temporarily not possible (for example, because your data has been stored in backup archives), then we will securely store your data and isolate it from any further processing until deletion or anonymisation is possible. When we anonymise data such as survey data, we will continue to use the anonymised data for our internal research purposes (e.g. to analyse and improve our Shopper Thoughts research services and products). and commercial purposes (e.g. to commercialise trends from our survey data through Shopper Thoughts).

12. Your data protection and privacy rights

12.1 You have the following rights:

(a) If you wish to access, correct, update or request deletion of your data, you can do so at any time by contacting us using the contact details provided under the “How to contact us” section below. If for any reason, you no longer wish to be a participant of Shopper Thoughts and wish to close your account with us, then please let us know using the contact details provided under the “How to contact us” section below, so that we can close your account and delete your account data. Please note that your account closure will not include the deletion of any survey data;

(b) In addition, you can object to our processing of your data, ask us to restrict our processing of your data or request portability of your data. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below;

(c) You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or equivalent link in the marketing e-mails we send;

(d) Similarly, if we have collected and process your data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your data conducted in reliance on lawful processing grounds other than consent; and

(e) You have the right to complain to the local data protection authority about our collection and use of your personal data. For more information, please contact your local authority. Contact details for authorities in the European Economic Area, Switzerland and certain non-European countries (including the US and Canada) are available here.

12.2 We respond to all requests we receive from individuals wishing to exercise their rights in accordance with applicable laws.

13. Updates to this Privacy Notice

13.1 We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you as appropriate in relation to the significance of the changes we make.

13.2 You can see when this Privacy Notice was last updated at the top of this Privacy Notice.

14. How to contact us

14.1 If you have any questions or concerns about our use of your data, please contact our Data Protection Officer using the following details: individualrights@dunnhumby.com.

14.2 The data controller of your data is dunnhumby Limited. If you are from certain countries or regions like Europe you also have the right to lodge a complaint or concern with your local data protection authority. You can find a list of the European data protection authorities here.