The policy is written as far possible in plain English, and arranged into 7 sections:
- Who we are
- What we collect
- Where we store it
- Who we may share it with
- Disclosing it
- Your rights
If you have any questions, comments, or suggestions for the policy you can get in touch with us on firstname.lastname@example.org or by writing to us at 51 Hoxton Square, London, N1 6PB.
2. Who we are
- NearSt Ltd is a retail technology company registered in England & Wales under company number 09524010.
- Our registered office is at 51 Hoxton Square, London N1 6PB.
- We are registered with the Information Commissioner's Office (the "ICO") under registration number ZA148327. You can look up the latest details with ICO at https://ico.org.uk/ESDWebPages/Search
- Our nominated data controller is Nick Brackenbury, CEO of NearSt Ltd.
3. What we collect
- We collect two types of information when we partner with you and work together to deliver our service to your shops. The first is "Personal Information" that we use to identify each of your shops and contact them about our service. The second is "Stock Information" that we use to run the service we provide to them.
- When we partner with you, we ask you to share basic information about each shop along with nominated points of contact within each shop in order to communicate with them as well as provide the NearSt service to them.
- We store the following Personal Information about each shop:
- The name of the business.
- The address of the business.
- Contact details for the business, such as email and telephone numbers.
- The names of nominated contacts provided by you for each business, or otherwise updated by the shop directly with us.
- Email and telephone numbers for the nominated contacts.
- Interactions each shop has with our customer support team via our email and website chat interface.
- Payment details provided to us directly by each shop in order to invoice them for use of the NearSt service.
- NearSt does not see or store any credit card information. This is handled by our payment provider, Stripe; an internationally recognised payment processing provider.
- You must not send NearSt any payment information you hold on file for any shop.
- Information about each shop's usage of the website, for example how often each shop logs into their MyShop account.
- We do not share the personal information of shops with any third parties, beyond what is absolutely required to deliver the services to shops as outlined in Section 5.
- We do not sell the personal information of your shops to any 3rd parties under any circumstances.
- To provide the NearSt service to each shop, we integrate with you as a POS partner to understand what products each shop stocks, in order to list them on other websites that will drive traffic to the shops, as well as show the shops information about how their customers are searching for their products.
- We store the following Stock Information about each shop to deliver this service:
- Barcodes, stock levels, and prices provided by our integration with you.
- Product information about those products, such as titles, descriptions, images, and categorisation sourced by NearSt.
- Search information provided by our Partners, showing how customers are searching for a shop's products.
- Search information provided by our Partners, showing which products customers are viewing and clicking on.
- We take the commercial sensitivity of this information very seriously, and never share it with our Partners without a shop's knowledge. Who we share any information with and under what conditions is described in more detail in Section 6.
4. Where we store it
- The information that we collect from you and your shops may be transferred to, and stored, outside of the European Economic Area ("EEA"). It may also be processed by providers and staff operating outside of the EEA. We will only transfer information outside of the EEA where allowed to do so by law.
- We take robust security measures to keep your and your shops' data secure, and require the same of all Partners and suppliers we work with.
- Where you login to the NearSt service with a password, it is your responsibility to keep it confidential and secure.
5. Who we may share it with
To run our business we outsource the processing of your and your shops' information to carefully selected third party providers, as well as Partners that are needed to deliver the NearSt service and drive footfall to shops. We vet these third party providers and Partners to ensure they have suitable security and data protection practices in place in order to protect your and your shops' data. We only share data necessary for the provider or Partner to deliver their service to us, in order for NearSt to deliver our service to you and your shops.
- We do not share commercially sensitive information about your business and any of your shops' businesses with any provider.
- We do not share information about your business and your client's businesses so that others may advertise to you or your shops.
- We do not share information with Partners without each shop's express consent.
- We share your data with third parties for the following reasons:
Communicating with your shops:
- We work with third party software providers to make it simpler for us to communicate with individual shops. These businesses include:
- Email service providers (i.e. Gmail).
- Customer support service and web chat providers (i.e. Intercom).
- Customer relationship management software providers (i.e. Hubspot).
- VOIP telephone service providers (i.e. CircleLoop).
Running our business:
- We work with operational third party providers who provide software to support the daily running of our business. These include:
- Accounting software providers (i.e. Xero).
- Payment processing providers (i.e. Stripe).
- Code management software providers (i.e. GitHub).
Providing our services:
- To deliver the NearSt service and the technology it runs on we work with a range of technology and cloud computing companies. These include:
- Cloud computing providers to process Stock Information (i.e. Google Cloud Platform).
- Error logging and management providers (i.e. Epsagon).
- Project management software providers (i.e. Monday.com).
- Shipping and postage providers (i.e. Royal Mail).
- Document printing providers.
- Analytics providers (i.e. Google Analytics).
Working with our Partners:
- To provide the NearSt service we work with different Partners. Each Partner only receives the minimum information required in order to provide their part of the service, in line with our Data Ethics policy and as described in each shop's Shopkeeper Agreement with NearSt.
- Where a Partner is an optional part of the NearS service, shops are clearly notified before their data is shared with them and have the ability to opt-out of sharing their data with that Partner. For example, a shop may want their Stock Information to appear in one search engine but not want it to appear in another search engine.
- The types of Partners we share shop's data with include:
- You as their POS provider:
- We only share basic Personal Information for you to identify each shop, so that you can correctly send the shop's Stock Information to us.
- We do not share commercially sensitive information about each shop with you, such as the performance of their products or their individual spend with NearSt.
- We may share aggregated and anonymised information about all the shops connected through you to help us improve our partnership and service, for example the total number of clicks across all the shops using your POS that are connected to NearSt.
- This does not include any information that could identify an individual business.
- This does not include any commercially sensitive information.
- Search, advertising and service Partners :
- Our search and advertising Partners list shops' stock information so that shoppers can find it, and help to drive additional footfall to each store. For example, Google will show a shop's products on their Google My Business page, and in Local Inventory Ads if the shop has NearSt PLUS active.
- Our service Partners allow shops to offer additional services from their shop, for example providing local delivery with a local courier service.
- These Partners receive basic business information in order to match a shop to one already held in their database (for example, business name and address details), and basic stock information, such as barcodes, product information, stock levels, and prices. Wherever possible we obfuscate exact stock levels by showing, for example "In stock", "low stock" and "out of stock" instead of exact stock positions.
- Shops can opt in and out of these Partners through their MyShop dashboard at https://myshop.near.st or by emailing email@example.com .
- Analytics Partners:
- Our analytics Partners see insights at an aggregated, anonymised level about groups of shops. For example, how many clicks bookshops as an industry are getting, or how many clicks all shops in London are receiving.
- We do not share any individual performance or commercial information about shops or POS partners (for example, how POS A is performing compared to POS B).
- We do not share any contact or business information about shops.
6. Disclosing it
- In a very limited set of circumstances we may be required to disclose your data or your shops' data to the following third parties:
Where legally required to do so:
- Sometimes we may be legally required to disclose your details or your shops' details, for example to law enforcement or when required to do so by a court. Where legally allowed to, we will always inform you if we have been asked to provide this information.
If we are selling our business:
- If NearSt is acquired by another company, we may be required to disclose details of the businesses we work with to them.
- If NearSt is acquired by another company, you will be notified and have the opportunity to delete your data prior to any acquisition taking place.
To other businesses owned by NearSt or within our group:
- We may choose to split NearSt into multiple individual companies as part of a group to make it more effective to deliver our service. If we do this, we will share your information within the group to continue delivering the service.
To protect against fraud:
- We may share your information with fraud prevention agencies to protect against financial crime and other credit risks.
7. Your rights
You can ask at any time to see the data we hold about your POS. To do so, simply email firstname.lastname@example.org and after verifying the authenticity of the request we will provide you with any information we hold about your business.
- We will also disclose which of your client shops we hold data for, and what types of data. We will not disclose commercially sensitive data, as per the terms in Section 5.
- We will keep this policy up to date, and notify you of any substantial changes to the policy via the email contact details we hold for you.
- If you have any questions, comments, or recommendations about this policy you can contact us by email on email@example.com or in writing at 51 Hoxton Square, London, N1 6PB.
- This policy references a number of terms, which are defined below:
- "Nominated contact(s)" means additional people within a shop that the shop has let us know we can communicate with about the shop.
- "The NearSt website", "our site", "the site", and "MyShop" means the NearSt website at https://near.st, including subdomains including the MyShop management dashboard at https://myshop.near.st.
- "NearSt service" means displaying a shop's Stock Information online on third party Partner websites and services with the intention of driving more footfall to the shop.
- "Partners" means third party companies who NearSt works with to list shop Stock Information online in order to drive more footfall into the shop.
Last updated: March 26, 2020