Privacy Policy

Last Updated: October 1, 2023

Naanac respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our site or app (”Site”).

ONE: IMPORTANT INFORMATION AND WHO WE ARE AND PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how Naanac collects and processes your personal data through your use of this Site, including any data you may provide through this Site when you sign up to our Site, browse or make a purchase via our Site, enter a competition or engage with us on our Site or through emails you may receive from us.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them. CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES This policy may change and be updated from time to time. In the event we plan to materially change how we use previously collected personal data, we will provide you with a notice and an opportunity to opt-out of such differing uses. Please check back regularly.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

This Site includes links to third-party Sites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party Sites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy notice of every website you visit.

TWO: THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data includes first name, last name, username or similar identifier, marital status and date of birth.

• Contact Data includes billing address, delivery address and email address.

• Financial Data includes bank account and payment card details.

• Transaction Data includes details about payments from you to retailers featured on our Site from time to time and other details of products and services you have purchased from such retailers via our Site.

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Site.

• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

• Usage Data includes information about how you use our Site, products and services.

• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Site feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice. Except in limited circumstances which will be made clear to you, we do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the Cash Back service). In this case, you will not be able to join Naanac.

THREE: HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact, Transaction or Financial Data by filling in forms or by corresponding with us by post, email or otherwise. This includes personal data you provide when you:

• create an account on our Site;

• submit a claim or enquiry about a transaction via our Site;

• enter a competition, promotion or survey; or

• give us some feedback

Automated technologies or interactions. As you interact with our Site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other Sites employing our cookies. Please see our Cookie Policy for further details. As you navigate our Site, we may collect Usage Data, Profile Data and Marketing and Communications Data as specified by you from time to time.

Essential Third parties. In order to facilitate the Cash Back service, we need to receive personal data about you from various third parties as set out below:

Technical, Transactional, Identity and Contact Data from the following parties:

a) Affiliate Networks; and

b) retailers featured on the Site from time to time

To help improve the service we provide and the functionality of our Site we may receive personal data about you from various third parties as set out below:

a) Technical Data from analytics providers such as Google; and

b) Contact and Technical Data where you join our Site as a result of our marketing activities involving third parties;

CHILDREN UNDER THE AGE OF 13

Our Site is not intended for individuals under 18 years of age. We do not knowingly collect personal data from consumers under 16. If you are under 16, do not use or provide any personal data on this Site. Additionally, if we learn we have collected or received personal data from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any personal data from or about a child under 13, please contact us at privacy@naanac.com.

FOUR: HOW WE USE YOUR PERSONAL DATA

We will use your personal data as set forth in the Privacy Policy and otherwise when you consent to such other uses:

• Where we need to perform the contract we are about to enter into or have entered into with you.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

What is a legitimate interest?

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience on our Site. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us privacy@Naanac.com.

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Within your account you can view and make certain decisions about your personal data use in relation to marketing emails.

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have signed up to our Site and you have not opted out of receiving marketing emails.

OPTING OUT

You can ask us to stop sending you marketing emails at any time by logging into your account on the Site and checking or unchecking relevant boxes to adjust your marketing preferences.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Site will become inaccessible or not function properly resulting in your Cash Back not tracking.

FIVE: DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.