Privacy Policy

The Chary on Top webiste (the “Site”) and the Chary on Top app (the “App”) (collectively, the “CoT Properties”) are operated by Chary on Top, a division of Smart Potato Limited (“we”/”us”/”our”), whose registered office is at 33 St. Lukes Road, London, England, W11 1DD (registered number: 09920612).

We take your privacy seriously and we want you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practices with respect to information that we or our third-party service providers collect through the CoT Properties. By providing Personal Information (as defined below) to us through the CoT Properties, you acknowledge that you have read this Privacy Policy and you understand the terms and conditions herein.

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third party, including Facebook, Inc., Apple Inc., Google LLC, Microsoft Corp., any wireless carriers and any third party operating any site or property to which any CoT Property contains a link. In addition, the inclusion of a link on any CoT Property does not imply endorsement of, or affiliation with, the linked site by us. Please note that the CoT Properties may include the ability to access and submit certain information directly to third parties, such as Facebook, or to any application platform, such as Apple's App Store or Google Play. Such information is submitted by you directly to such third parties and this Privacy Policy does not apply to any such information submitted by you.

What personal data do we collect?

We may collect personal identification data (“Personal Information”) from you in a variety of ways, including, but not limited to, when you visit the CoT Properties, register for an account, make a donation or subscribe to the Chary on Top newsletter and in connection with other activities, services, features or resources we make available on our site.

We may collect some or all of the following personal data about you:

Name
Username and password
Postal address
Telephone Number
Email address
Payment (typically credit card or debit card) details
Correspondence to and from Chary on Top
Data about your use of the CoT Properties.

We may also collect some of this personal data from third parties who have your consent to pass your details to us. We may automatically collect non-personal data about your use of the CoT Properties. For example, we may automatically log which parts of the CoT Properties you access and the website from which you linked to the CoT Properties. You cannot be identified from any of this data. It enables us to compile statistics about the use of the CoT Properties, and to help target aspects of the CoT Properties and advertising to you more accurately.

Collection of Personal Information

We and our third-party service providers collect Personal Information through the CoT Properties in a variety of ways, including:

Through the CoT Properties
- We may collect Personal Information through the CoT Properties, for example, when you register for newsletters or other communications through the CoT Properties, make a purchase or make a request.
From Other Sources
- We may receive your Personal Information from other sources, for example:
  - publicly available databases; or
  - marketing partners when they share information with us in the context of marketing and promotional campaigns related to our business.
- If you use your social media or other third party account to enter our promotions or via an initiation to sign into such account on our CoT Properties, you will share certain Personal Information from your third party account with us which may include, for example, your name, email address, photo, list of social media contacts, and any other information that you make or which is otherwise accessible to us when you connect through such third party account.

You are not required by statute or contract to provide any Personal Information to us. Providing Personal Information is voluntary but it is essential in order to facilitate your use of the CoT Properties. For example, when you participate in various opportunities provided through the CoT Properties, we collect Personal Information from you in order to enable you (or us) to complete your experience on the CoT Properties.

How do we use collected data?

When you sign up to Chary on Top and agree to our User Terms of Service, we and our third-party service providers use your Personal Information for the following purposes:

Providing the functionality of the CoT Properties and fulfilling your requests.

To provide the CoT Properties’ functionality to you (for example, arranging access to your registered account and providing you with related customer service).
To process transactions when making a donation.
To contact you by email and/or mobile communication for administrative purposes (for example, to notify you of any changes to our terms, conditions and policies) and in accordance with your requests and support needs.
To allow you to participate contests and similar promotions using your email address, and to administer these activities. Some of these activities have additional rules, which could contain additional information about how we use and disclose your Personal Information, so we suggest that you read these rules carefully; in the event of a conflict between such rules and this Privacy Policy, such rules will govern.

We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

Providing you with our newsletter and/or other marketing materials and facilitating social sharing

To send you marketing communications that we believe may be of interest to you if you have indicated that you would like to receive them (including, without limitation, by our third-party service providers that send direct mail, email and other types of advertising).
To send you SMS text messages using your telephone number, e.g., if you participated in a promtion with this number and you have indicated you would like to receive them. Please keep in mind that message and data rates may apply. You should check with your mobile service provider for applicable data rates.
To allow you to send messages to a friend through the CoT Properties. By using such functionality, you are telling us that you are entitled to use and provide us with your friend's name and email address.
To facilitate social sharing functionality that you choose to use.

We will engage in this activity with your consent.

Analysis of Personal Information

To personalize your user experience and to understand how our users as a group use the services and resources provided on the CoT Properties.
To improve our website based on the data and feedback we receive from you.
To aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose.

We will provide personalized services either with your consent or because we have a legitimate interest.

Disclosing your personal data

To enable us to provide our service, we share data with the following categories of organisations:

To our third party service providers to facilitate the service they provide to us: these can include providers of services such as hosting, data analysis, payment processing, IT services, fraud prevention or other similar services.
To UK registered charities, exempt charities or community amateur sports clubs (CASCs) relevant to you.
To third parties, to permit them to send you marketing communications, consistent with your choices.

Additionally, by using the CoT Properties you may elect to disclose Personal Information to the general public, for example, through message boards, chat, profile pages, blogs or other services to which you are able to post information and materials. Please note that any information and materials that you post or disclose on or through a CoT Property will become public information and may be redistributed through the Internet and other media channels where they will reach an even broader audience. We urge you to be very careful when deciding to disclose your Personal Information on or through the CoT Properties. WE ARE NOT RESPONSIBLE FOR THE USE OR DISCLOSURE OF ANY INFORMATION YOU VOLUNTARILY DISCLOSE THROUGH ANY CoT PROPERTY.

Other Uses and Disclosures

We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:

To comply with applicable law.
To respond to requests from public and government authorities.
To cooperate with law enforcement.
For other legal reasons, for example:
- To enforce our terms and conditions;
- To protect our operations or those of any of our affiliates;
- To protect our rights, privacy, safety or property, or that of our affiliates, you or others; or
- To allow us to pursue available remedies or limit the damages that we may sustain.
In connection with a sale or business transaction. We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings) Such third parties may include, for example, an acquiring entity and its advisors.

Retention and deletion of personal data

We will not retain personal data longer than is necessary to fulfil the purposes for which it was collected or as required by applicable laws or regulations.

Sensitive Information

We ask that you not disclose to us any sensitive Personal Information (e.g., national insurance numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through the CoT Properties or otherwise.

Safeguarding personal data

We will use reasonable physical, technical and administrative measures to protect Personal Information under our control. If you have reason to believe that your interaction with us is no longer secure, please notify us immediately in accordance with the “Contacting Us” section below.

An account on the CoT Properties requires a username and password to log in. You must keep your username and password secure, and never disclose it to a third party. Your account passwords are stored in an encrypted format and we cannot see or resend forgotten passwords.

Breaches of security

If a security breach causes unauthorized access into our system that affects your personal data, we will notify you as soon as possible and later report the action we took in response.

Access to your data

We will give you access to any Personal Information we hold about you within 30 days of any request for such data in accordance with applicable law. You may request to access, correct, amend or delete data we hold about you by contacting us in accordance with the “Contacting Us” section below.

Subject to applicable data protection legislation, we will remove any personal data we hold about you from our servers at your request. There is no charge for access or updating personal data.

Your rights

Under the EU General Data Protection Regulation 2016/679 (GDPR) you have a number of rights you can exercise regarding privacy and the protection of your data. These include:

The right to be informed about the collection and use of your personal data.
The right of access to personal data, free of charge.
The right to have inaccurate personal data rectified, or completed if it is incomplete.
The right to have personal data erased in certain circumstance.
The right to request the restriction or suppression of your personal data.
The right to obtain and reuse personal data for your own purposes across different services.
The right to object to the processing of your personal data in certain circumstances.
Rights in relation to automated decision making and profiling.

Additionally, you have the right to lodge a complaint regarding data protection with the Information Commissioners Office in the UK via https://ico.org.uk

Changes to this privacy policy

We may change this Privacy Policy at any time. We encourage you to frequently check this page for any changes to stay informed about how we are helping to protect the Personal Information we collect. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically and become aware of modifications.

Acceptance of this notice

By using any of the CoT Properties, you signify your acceptance of this Privacy Policy and the User Terms of Service. If you do not agree to this Privacy Policy, please do not use the CoT Properties. Your continued use of the CoT Properties following the posting of changes to this Privacy Policy will be deemed your acceptance of those changes.

Contact information

We, Smart Potato Limited, are the company responsible for collection, use and disclosure of your Personal Information under this Privacy Policy.

If you have any questions or concerns about this Privacy Policy or our data processing practices, please contact us by email at [email protected]. Alternatively, if you are located within the EU/EEA, you may also lodge a complaint with a data protection authority for your country or region, or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available here.

We are located at the following address:

Chary on Top

Smart Potato Limited

33 St Lukes Road

London

England

W11 1DD

Please note that email communications are not always secure, so please do not include credit card information or other sensitive information in your email messages to us.