ABOUT US

At Poncho Care Limited, we are committed to respecting your privacy. This Privacy Policy explains how we collect, use and disclose personal information that we receive when you use our Poncho platform (whether through our website, www.poncho.care, or the Poncho app), visit our website, use our services, or communicate with us, both on this website and offline as a customer or potential customer.

It is important that you read this Privacy Policy so that you are fully aware of how and why we are using your data.

When we refer to the“Company”, “we”, “us” or “our” in this Privacy Policy, we are referring to  Poncho Care Limited, which is registered as a data controller with the Information Commissioner’s Office under data protection registration number ZA793696.

When we refer to “Poncho”in this Privacy Policy, we are referring to our website, www.poncho.care and the Poncho platform which is accessible from our website & our web app app.poncho.care.

CONTACTING US

If you have any questions about our Privacy Policy or your information, or to exercise any of your rights as described in this Privacy Policy or under data protection laws,you can contact us as follows:
Poncho Care Limited
FAO: Ben Prouty, 9, Mandeville Place, London W1U 3AY
By email:  support@poncho.care

Data Protection Principles

We adhere to the following principles when processing your personal information as data controller:

  1. Lawfulness, fairness and transparency: data must be processed lawfully, fairlyand in a transparent manner.
  2. Purpose limitation: data must be collected for specified,explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
  3. Data minimisation: data must be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
  4. Accuracy: data must be accurate and, where necessary, kept up to date.
  5. Storage limitation: data must be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal information are processed.
  6. Integrity and confidentiality: data must be processed in a manner that ensures appropriate security of the personal information, including protection against unauthorised or unlawful processing and against accidental loss,destruction or damage by using appropriate technical or organisational measures.

PERSONAL INFORMATION WE COLLECT

Information you give us when using Poncho.
When registering a Poncho account, you must provide us with your name and email address.  Other optional information that you may add to your account includes your needs and interests,children's ages, your local area and job title.

You must also provide us with certain personal information when you access certain services or book an activity or redeem a benefit through Poncho.  For example, you may need to provide your payment card details if you are purchasing the activity.  Where applicable for bookings involving your children, you may be required to provide your children’s names and age (this is optional if the activity provider permits bookings to be made in the parent's name instead).

Payment information
Activities on Poncho can be paid for using pre-paid credits that are purchased by your employer, or using your own payment method.  We use a third party payment processor, Stripe, to handle payments for us on Poncho. This means that we do not retain your debit or credit card information.  Instead, Poncho enables you to provide these details directly to Stripe.  Stripe’s privacy policy can be found here.

Information you give us in your other dealings with us
In addition, you may provide us with information by email, over the phone or when you otherwise contact us.  For example when:
1. you request additional information about our business or ask us to contact you;
2. we provide our services to you and/or enter into transactions with you; or
3. you send any other information about you to us.

The categories of personal information you provide may include first and last name, job title and company name, address, phone number and email address.

We do not generally seek to collect sensitive personal information through Poncho or as part of our business transactions. Sensitive personal information is information relating to racial or ethnic origin; political opinions; religious or philosophical beliefs; trade-union membership; health;sex life, sexual orientation; or genetic or biometric information. If we do collect sensitive personal information, we will ask for your explicit consent to our proposed use of that information at the time of collection.

Information we collect from you
We collect, store and use information about your visits to and use of Poncho, and about your computer, tablet, mobile or other device through which you access Poncho. This includes the following information:· 
1. details of transactions you carry out through Poncho and of the fulfilment of your orders;
2. technical information, including the Internet protocol (IP) address, browser type,internet service provider, device identifier, your login information, time zone setting, browser plug-in types and versions, preferred language, activities,operating system and platform, and geographical location; and
3. information about your visits and use of the website, including the full Uniform Resource Locators (URL), clickstream to, through and from our website, pages you viewed and searched for, page response times, length of visits to certain pages,referral source/exit pages, page interaction information (such as scrolling,clicks and mouse-overs), date and time pages are accessed, and website navigation and search terms used.

Information we collect from your employer
Access to Poncho is only granted to employees and  other workers of Poncho’s clients including temporary, agency or contract workers, interns,volunteers and independent contractors.  Your employer may provide us with your name and business email address so that we can tell you that you are eligible for a Poncho account. We hold this data as processor for your employer and will not use this data for any other purpose unless and until you subscribe for an account with Poncho.

Your employer will also tell us the amount of any Poncho credit which has been provided by your employer to you for use on Poncho.

Aggregated Data
We may also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. For example, we may use Aggregated Data to publish report on trends in the usage of Poncho and our applications and services. Aggregated Data could be derived from your personal information but is not considered personal information as this data will not directly or indirectly reveal your identity.

Children
Poncho is a platform aimed at parents and young adults. It is not intended for or directed at children under the age of 18 years.  When using Poncho, parents have the option of providing their children’s names or ages to us. Children’s names are used by us for the purpose of booking activities requested by the parents only, while their ages are only used to suggest age-appropriate activities to parents.   Other than this,we do not knowingly collect information relating to children under the age of 18 years.

WHAT WE DO WITH YOUR PERSONAL INFORMATION

As data controller, we will only use your personal information if we have a legal basis for doing so. The purpose for which we use and process your information and the legal basis on which we carry out each type of processing is explained in the table below.

Legal Basis for the processing

Purposes for which we will process the information

To enable you to register an account on, access and use Poncho and to allow us to supply services to you.

It is necessary for us to process your personal information in this way in order to enter into a contract with you and to fulfil our contractual obligations to you.

To arrange the booking, and payment of  activities, as requested by you on Poncho.

It is  necessary for us to process your personal information in this way in order to  enter into a contract with you and to fulfil our contractual obligations to  you. 

To carry out  our obligations arising from any contracts entered into with you, and to  perform our services for you.

It is  necessary for us to process your personal information in this way in order to  enter into a contract with you and to fulfil our contractual obligations to  you. 

To send you promotional materials and other materials that may be of interest to you, including information about Poncho, us, our services, events or general promotions

It is  necessary for our legitimate interests to develop our services and grow our  business. To ensure we offer an efficient service, we consider this use to be  proportionate and will not be prejudicial or detrimental to you.  You can unsubscribe or opt-out from  receiving these communications at any time by clicking the “unsubscribe” link  in the email.

To provide you with information and materials that you request from us.

It is in our legitimate interests to respond to your queries and provide any information and materials requested in order to generate and develop business.

To manage payments, fees and charges and collect and recover money owed to us; to communicate about billing issues; or to enforce any contracts entered into with you.

It is in our legitimate interests to process your personal information in this way in order to perform or enforce our contract with you.

To send you  information regarding changes to our policies, other terms and other administrative information such as reminders, technical notices, updates and  security alerts.

It is in our legitimate interests to ensure that any changes to our policies, terms and other such technical updates are communicated to you.

To: administer our website including resolving technical issues, troubleshooting, data analysis, testing, research,statistical and survey purposes; and improve our website to ensure that content is presented in the most effective manner for you and your computer, mobile device or other item of hardware through which you access Poncho.

For both these categories, it is in our legitimate interests to continually monitor and improve our services and your experience of the website and platform and to ensure network security.

To help create and maintain a trusted and safe environment on the website and platform by, among other things, detection and prevention of fraud and other harmful activity,conducting investigations and risk assessments, verifying any identifications provided by you, and conducting checks against databases and information sources for fraud detection and prevention, risk assessment and harm prevention purposes.

It is in our legitimate interests to carry out such checks to ensure prevention against fraud and other harmful activity and that our website and platform is safe and secure.

Generally, we do not rely on consent as a legal basis for processing your personal information although we may need your consent before sending direct marketing communications to you via email or text message where you are not an existing user.  Where you provide consent, you can withdraw your consent at any time and free of charge, but without affecting the lawfulness of processing based on consent before its withdrawal. You can update your details or change your privacy preferences by contacting us as provided in the Contacting Us section above.

DISCLOSURE OF YOUR PERSONAL INFORMATION TO PONCHO PARTNERS

Poncho is an online learning and activities platform for children and young adults, which includes an online marketplace connecting users with a selection of hand-picked third party service providers who offer activities, events, learning opportunities, after school and holiday clubs, and other services and products for children and families (“Poncho Partners”).  We will disclose your name, email address and, if requested by you, the name of your child taking part in the activity to the Poncho Partner for the purpose of booking an activity with such Poncho Partner. The Poncho Partner will have its own privacy policy which should set out how the Provider will use your personal information.  We do not accept any responsibility or liability for this policy. Please check the Poncho partner’s policies before you submit your booking request.

DISCLOSURE OF YOUR PERSONAL INFORMATION TO OTHER THIRD PARTIES

We will not sell, rent, lease or otherwise share your personal information other than as outlined in this Privacy Policy or without obtaining your consent beforehand.
We will share your personal information with any member of our group of companies insofar as reasonably necessary for the purposes set out in this Privacy Policy.
Personal information will also be shared with our third party service providers who assist with the running of Poncho and the operation of our business and who process personal data on our behalf, including third party hosting providers and payment processors.

Name

Purpose

Location

Segment

Platform usage data aggregator. To streamline and pre-process capture of usage analytics. To improve the platform and the experience.

USA

Mixpanel

Platform usage analytics. To improve the platform and the experience.

EU

Auth0

To handle platform authentication.  Sensitive data (passwords, login info), are stored in a highly secure  environment and do not touch our servers.

EU

SendGrid

For email automation, of transactional emails such as login and booking.

USA

Heroku

Platform hosting and data storage.

EU

Sentry

Platform error logging.

USA

Hubspot

Customer support live chat. (Marketing website)

USA

Intercom

Customer support live chat (web  app)

USA

Facebook

Torun ads, generate publicity and get leads for Poncho

Ireland,USA

Stripe

Third party payment processor

Ireland

Our third party service providers and business partners are subject to security and confidentiality obligations and are only permitted to process your personal information for specified purposes and in accordance with our instructions.

In addition, we may disclose information about you:

INTERNATIONAL TRANSFERS

Where we collect personal information from you, it may be necessary for us to transfer your personal information outside of the UK or the European Economic Area (“EEA”) to Poncho Partners, our service providers and other business partners located outside the UK or the EEA.

Where personal information is transferred to and stored in a country not determined by the UK or the European Commission as providing adequate levels of protection for personal information, we take steps to provide appropriate safeguards to protect your personal information, including entering into standard contractual clauses approved by the UK or the European Commission,obliging recipients to protect your personal information.

If you would like further information on the specific mechanism used by us when transferring your personal information outside of the UK or the EEA,please contact us using the details set out in the Contacting Us section above.

SECURITY OF PERSONAL INFORMATION

We use appropriate technical and organisational security measures to protect personal information both online and offline from unauthorised use, loss, alteration or destruction. We use physical and procedural security measures to protect information from the point of collection to the point of destruction. Where data processing is carried out on our behalf by a third party, we take steps to ensure that appropriate security measures are in place to prevent unauthorised disclosure of personal information.

Despite these precautions, however, we cannot guarantee the security of information transmitted over the Internet or that unauthorised persons will not obtain access to personal information.

HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We will only retain your personal information 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 information 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 information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

YOUR RIGHTS
ACCESS TO AND UPDATING YOUR PERSONAL INFORMATION

You have the right to access information which we hold about you (“data subject access request”).

You may also have the right to receive personal information which you have provided to us in a structured and commonly used format so that it can be transferred to another data controller(“data portability”). The right to data portability only applies where your personal information is processed by us with your consent or for the performance of a contract and when processing is carried out by automated means.We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate. Please keep us informed if your personal information changes during your relationship with us.

RIGHT TO OBJECT

Direct marketing
You have the right to object at any time to our processing of your personal information for direct marketing purposes.

Where we process your information based on our legitimate interests
You also have the right to object, on grounds relating to your particular situation, at any time to processing of your personal information which is based on our legitimate interests. Where you object on this ground, we shall no longer process your personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

YOUR OTHER RIGHTS

You also have the following rights under data protection laws to request that we rectify your personal information which is inaccurate or incomplete.

In certain circumstances, you have the right to request the erasure of your personal information: this enables you to ask us to delete or remove personal information where there is no good reason for us to continuing to process it (“right to be forgotten”); and restrict the processing of your personal information.

Please note that the above rights are not absolute and we may be entitled to refuse requests, wholly or partly,where exceptions under the applicable law apply. For example, we may refuse a request for erasure of personal information where the processing is necessary to comply with a legal obligation or necessary for the establishment, exercise or defence of legal claims. We may refuse to comply with a request for restriction if the request is manifestly unfounded or excessive.

EXERCISING YOUR RIGHTS

You can exercise any of your rights as described in this Privacy Policy and under data protection laws by contacting us as provided in the Contacting Us section above.

Save as described in this Privacy Policy or provided under data protection laws, there is no charge for the exercise of your legal rights. However, if your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either: (a) charge a reasonable fee taking into account the administrative costs of providing the information or taking the action requested; or (b)refuse to act on the request.

Where we have reasonable doubts concerning the identity of the person making the request, we may request additional information necessary to confirm your identity.

COOKIES

In order to improve the website, we may use small files commonly known as “cookies”. A cookie is a small amount of data which often includes a unique identifier that is sent to your computer or mobile phone (your “device”) from the website and is stored on your device’s browser or hard drive.

By continuing to browse the website, you are agreeing to our use of cookies.

If you do not want us to use cookies when you use the website, you can set your internet browser not to accept cookies.However, if you block cookies some of the features on the website may not function as a result.

You can find more information about how to do manage cookies for all the commonly used internet browsers by visiting www.allaboutcookies.org. This website will also explain how you can delete cookies which are already stored on your device.

We ask for your consent to place cookies on your device, except where these are essential (strictly necessary) for us to provide you with a service that you have requested.

Strictly necessary cookies:
We currently set the following cookies which are strictly ncecessary for provision of our service:

First Party Cookies

Cookies Names(s)

Purpose

Poncho

search

To persist search term entry while navigating the Poncho app

Poncho

filters

To persist selected product filters, such as age, category, while navigating the Poncho app

Poncho

filterParams

To persist selected product filter parameters,such as specific selected categories or age ranges, while navigating the Poncho app

Third Party Cookies

Cookie Name(s)

Purpose

Link

Auth0

auth0.is.authenticated
_legacy_auth0.is.authenticated

To detect if user is logged in/authorised or not

Auth0Privacy Policy

Stripe

__stripe_sid
__stripe_mid

To enable payment for products and services.

Stripe Privacy Policy

Hubspot

__hs_opt_out
__hs_do_not_track
__hs_initial_opt_in
__hs_cookie_cat_pref
hs_ab_test
<id>_key
hs-messages-is-open
hs-messages-hide-welcome-message
__hsmem
hs-membership-csrf
hs_langswitcher_choice
__cfduid
__cfruid

These cookies remember to ask visitors not to accept cookies again, prevent tracking code from sending information to hubspot,prevent banner from displaying in strict mode, record categories visitor has consented to, help with a/b testing, not require logins for future visits,determine and save whether chat widget is open for future, prevent chat widget from appearing after it is dismissed, identifies user when they are logged in,ensures content membership logins cannot be forged, save language choice,detect malicious visitors and minimize blocking of legitimate users(Cloudflare)and help with rate limiting policies of CDN provider

Hubspot Privacy Policy

Non-essential cookies from third parties
We currently use the following (non-essential)third party cookies:

Third Party Cookies

Cookie Name(s)

Purpose

Link

Google Analytics

_gat_gtag_UA_177259953_1
_gid
_ga

Marketing website (www.poncho.care) only.These cookies provide us with a visitor count and an understanding of how visitors move around and use the website. We can then use this information to improve navigability and the website generally.

Google Privacy Policy

Hubspot

__hstc
hubspotutk
__hssrc
__hssc

These cookies help us track visitors, their identities, keep track of sessions and to check if users have restarted their browsers.

Hubspot Privacy Policy

Segment

ajs_anonymous_id
ajs_user_id

These cookies  enable us to recognise device data, such as your computer or mobile  device operating system type and version number, manufacturer and model,  browser type, screen resolution, IP address, unique identifiers, and general  location information such as city or town.They also  enable us to monitor usage data, such as the website you visited  before browsing to the Site, pages or screens you viewed, how long you spent  on a page or screen, navigation paths between pages or screens, information  about your activity on a page or screen, access times, and duration of  access. 

Segment Privacy Policy

Intercom

intercom-id-wrjyci8v
intercom-session-wrjyci8v

These cookies help us track visitors, their identities, keep track of sessions and to check if users have restarted their browsers.

Intercom Privacy Policy

Facebook

_fbp
fr

Targeting cookies which allow us to place advertising content onto Facebook that is relevant to you based on your browsing patterns on our website. This information is never connected to your profile and it is always anonymous.

Facebook Privacy Policy

Youtube

VISITOR_INFO1_LIVE
LOGIN_INFO
YSC
SID
HSID
__Secure-3PSID
__Secure-3PSIDCC
SSID
APISID
SAPISID
__Secure-3PAPISID

These cookies  enable us to embed product videos via YouTube. They are used by youtube to  track which videos are watched, to keep progress and enable recommendations.  Youtube uses this data to improve it’s service.

Google Privacy Policy

COMPLAINTS
If you have any questions or concerns regarding our Privacy Policy or practices, please contact us as provided in the Contacting Us section above. You also have the right to complain to the UK Information Commissioner’s Office (https://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.

CHANGES TO OUR PRIVACY POLICY
We reserve the right to change this Privacy Policy from time to time. Any changes will be posted on the website with an updated revision date. If we make any material changes to this Privacy Policy, we may notify you by email or by means of a prominent notice on the website prior to the change becoming effective.



Date: 29-11-2020