Revised 3 July 2023
1.1 Chillisalsa Limited (trading as Ailuna), a company registered in England and Wales (Company Number 09440691) with its registered address at Inca, The Lane, Lyford, Wantage OX12 0EE, United Kingdom, which operates websites and mobile applications (“Apps”) and other products and services thereof (together referred to as the “Products”) under the name “Ailuna”, which includes our business offering, “Ailuna for Business”.
1.2 Ailuna aims to provide a sustainability product which drives employee, customer, citizen and student sustainability engagement and action and makes it fun to develop impactful habits that are good for individuals, teams and the planet, helping reduce the CO2 and environmental footprints of individuals and organizations.
1.3 We believe strongly in protecting our users’ information and want to reveal openly how Ailuna, through its platform, app or website, collects, handles and processes data of its customers and visitors, and where that information is shared with third parties.
2 Scope and Purpose
3.2 Data Protection Officer: Ailuna’s data protection officer can be contacted by email at firstname.lastname@example.org
4 Types of Data we Collect
4.1 All data we collect is required under legitimate interest in order to deliver a functional, compelling and relevant service designed to help users adopt and maintain more sustainable lifestyles as well as educate them and keep them informed about associated news and events.
4.2 We collect both Personal Data and Other Information in support of these efforts.
4.3 “Personal Data” is information that can be used, directly or indirectly, alone or together with other information, to identify you as an individual User. This may include your precise Location Data. The submission of your Personal Data to us is voluntary in order to be able to use Ailuna. The consequence of not submitting Personal Data may be that you cannot use Ailuna or functionality will be limited or broken.
4.4 “Other Information” is information that is anonymous, aggregate, de-identified, or otherwise does not reveal your identity. Some examples include age, gender, browser and operating system, time spent using our Services, and webpages visited. We collect and use this information to understand how you and our users as a whole use our Services and constantly tune, enhance, innovate and build products and services to reflect the needs of our users.
5 Data Collection
5.1 We collect Personal Data in the following ways:
5.1.1 When you register with Ailuna, you provide your first name, last name and your email address and password. We try to automatically detect your location, based on your device settings and where you are geographically located at the time of registration. This information you can overwrite if desired. You may also provide additional information, such as your city and county/state, although this is optional.
5.1.2 Additionally, we encourage you to indicate which sustainability choices you have made, which may help us provide a better and more relevant service to our users, and for users to seek relevant advice and guidance from other users with experience in the topics they are interested in. All such information fields are available to you, and capable of being changed, through the Profile page, as well as you can control which information is kept private vs. shared.
5.1.3 When you use or interact with our Services, we collect Personal Data such as Location Data. We may use your Location Data to provide a more relevant service. This may include showing you a map or list view of nearby 2nd hand, charity, refill or other sustainability stores, groups and events and suggesting the most relevant stores, groups and events for you. We may also use your Location Data to conduct analytics to improve Ailuna.
5.2 We collect Location Data in several ways:
5.2.1 From your wireless carrier (i.e. your physical location at the time you register)
5.2.2 Directly from the device on which you use our Services, through its device settings.
5.2.3 The way in which we collect Location Data is different depending on whether you are accessing Ailuna through a mobile app or a website.
5.2.4 If you are accessing Ailuna through our mobile app, the way we collect Location Data will differ depending on your mobile device’s operating system. In all events, we do not collect Location Data, unless you have allowed its collection when prompted. If you decline to allow Location Data collection in the app, we will not collect your Location Data unless you manually enter it in
5.3 When you take surveys and/or enter contests, we may collect contact, demographic and eligibility information.
5.4 We may sponsor contests and other promotions and we may request that you provide Personal Data, such as name, address, email address, telephone number and age and other information that may be appropriate in order to participate.
5.5 We may also launch surveys that ask you to answer questions about a range of topics from personal information to behaviour, sustainability, brand and product preferences.
5.6 We process this Personal Data based on your consent, pursuant to GDPR article 6 (1) (a) or because it is necessary for the purposes of the legitimate interests pursued by us in order to improve our Product, pursuant to GDPR article 6 (1) (f)
6 How we use your Personal Data
6.1 Service emails and mobile push notifications “Service Messages” are used to provide you with a good service experience. These Service Messages include the following:
6.1.1 Welcome emails – welcome e-mail containing a link to verify your e-mail.
6.1.2 Key service messages – if we need to notify you about changes to the service.
6.1.3 Notifications necessary for our sustainability and behavioural change programs to work, including tips & tricks.
6.1.4 Useful sustainability and environmental news and information
6.1.5 New friend notifications – when you have friend invitations pending or accepted friend invitations.
6.1.6 Social community & content updates – for example when friends and other Ailuna users post new content or comment on yours.
6.1.7 Service suspension notices – if you break our rules around acceptable content (images, video and text).
6.2 Other Ailuna relevant emails and notifications.
6.2.1 Newsletters. When registering, you are given the option to receive our occasional newsletters. We use these to notify you about new features, ask your opinion about the mobile app and website. We only send a newsletter when there is something worthwhile to tell you about or if we need your feedback to improve our service. You can update your newsletter preferences in the app.
6.4 We do not provide our advertising partners, if any, or any third parties with information that identifies you as an individual.
7.1 We want you to feel confident about using our Products, and we are committed to protecting the personal information we collect. When using Ailuna for Business we limit access to personal information about you, as an employee, to your employer who may reasonably need access to it, to ensure that our Products function to your and your employer’s mutual satisfaction.
7.2 We have appropriate technical and organisational physical, electronic, and procedural safeguards to protect the personal information that you provide to us against unauthorised or unlawful processing and against accidental loss, damage or destruction. However, where we ask you to choose a password in order to access certain parts of our Product, you are responsible for selecting a secure password and keeping that password confidential. You should choose a password which you do not use on any other site, and you should not share it with anyone else.
8 Where we store your Personal Data
8.1.1 Hosting service providers: Our mobile app user databases (SQL and NoSQL) are hosted with Google Cloud in Frankfurt (Germany) and London (UK) and managed by our R&D partner Meetle GmbH (Leipzig, Germany).
8.1.2 Mobile app analytics: We use Google Analytics hosted with Google Cloud in Frankfurt (Germany) and London (UK) along with Amplitude (USA)
8.1.3 Newsletter e-mail and CRM (customer relationship management) providers: We currently use Copper CRM and Active Campaign, located in the USA, but this may change in the future.
9.2 Cookies. We use small text files known as “cookies” to enhance your experience of our service as follows:
9.2.1 To hold your login information (mentioned above), so that you do not need to log in each time you visit the mobile app and website, and your homepage is personalised. This option can be turned off by logging out.
9.2.2 To facilitate optimal use of our service by means of a temporary “session” cookie which helps you to navigate through the mobile app and website and enhances your user experience. These cookies disappear when your browser session ends, or when you click the “Signout” link on the mobile app; and
9.2.3 To help us recognise you as a unique visitor by means of a “persistent” cookie when you return to our mobile app and website and to allow us to tailor content to match your preferred interests or to avoid showing you the same messages repeatedly.
9.3 Analytical cookies. We also use analytical cookies and similar analytical tools to compile anonymous, aggregated statistics that allow us to understand how users use our service and to help us improve the structure of our mobile app and website. This is not Personally Identifiable Information (PII), and we cannot identify you in this way. These cookies allow us to understand who has seen which pages, to determine how frequently particular pages to determine the most popular areas of the mobile app and website, and generally to monitor usage of the mobile app and website. We will also use aggregate non-personal data to track the success of any advertising campaigns on our mobile app and website, to improve the effectiveness and suitability of advertising in communications sent by us and other companies in the Ailuna group and/or to provide to third parties anonymised, demographic data provided by you to target advertising more appropriately.
9.5 Further information. Please use the details in Contact Us to request further details about individual cookies used on our mobile app and website by us and by third parties.
9.6 Disabling cookies. Most internet browsers are automatically set up to accept cookies, but you can set your browser to refuse a cookie by changing your browser security settings, or you can ask your browser to show you where a cookie has been set up. You may also be asked to consent to the use of certain cookies upon entering or registering on our mobile app and website. Certain features on our mobile app and website are only activated by the presence of a cookie so, if you do not accept certain cookies, our mobile app and website will not work properly. You can find out more on how to disable/enable cookies via the following link https://allaboutcookies.org.
10 Your data Rights
10.1 Your rights: Subject to exceptions under applicable law, you may have certain choices regarding our use and disclosure of your personal information, as described below:
10.1.1 Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected about you during the past 12 months and details regarding our collection, use, disclosure and sale, if any, of such information.
10.1.2 Deletion: You have the right to request that we delete certain personal information we have collected from you.
10.2 To exercise your rights, please use the details in Contact Us. In order to process your request we may require you to provide certain information to verify your identity (such as your name, email address, phone number and/or address) or the authority of any third person acting on your behalf.
10.3 For users in the United States: California Privacy Rights
10.3.1 This section applies solely to the personal information collected online and offline of California consumers (excluding employees, applicants, staff and contractors). This section is intended to address the relevant notice requirements of the California Consumer Privacy Act of 2018 (the “CCPA”) and uses certain terms that have the meaning given to them in the CCPA.
10.3.3 Sharing your information: We may have shared your personal information with certain categories of third parties, as described in the section headed “Where we store your Personal Data” above.
10.3.4 Selling your information: We do not sell personal information in exchange for monetary compensation.
10.3.5 No discrimination: If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. This section is available in alternative formats upon request using the details in Contact Us.
10.3.6 Personal, family and household clients: In addition, under California Civil Code Section 1798.83, if you are a California resident and your business relationship with us is primarily for personal, family or household purposes, you may request certain data regarding our disclosure, if any, of personal information to third parties for the third parties’ direct marketing purposes. To make such a request, please send an e-mail message to our e-mail address below with “Request for California Privacy Information” in the subject line. You may make such a request up to once per calendar year. If applicable, we will provide you, by e-mail, a list of the categories of personal information disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, along with the third parties’ names and addresses. Please note that not all personal information sharing is covered by Section 1798.83’s requirements.
10.4 International transfers
10.4.1 Where we share your information with a third party service provider outside of the European Economic Area and Switzerland (as detailed in the section entitled “Where we store your Personal Data”), we contractually oblige the third party service providers, through their respective Privacy Policies, to implement adequate safeguards to protect your information.
11 Disclosure of Data
11.1 We do not share personal information about you with other people or non-affiliated companies except under the following circumstances:
11.1.1 We will disclose your personal information to third party providers for the purposes of providing online services, and any other services required in order for us to use your information for the purposes specified in the section entitled “How we use your Personal Data”.
11.1.2 We will disclose your personal information to any law enforcement agency, court, regulator, government authority or other third party where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.
11.1.3 Where you are using the services as part of Ailuna for Business, we may share your calculated environmental impact information (e.g. your carbon footprint), your Ailuna score in the form of “XP Points”, the type and the overall number of actions that you have committed to and completed with your employer, the “Ailuna For Business Client”. The Ailuna for Business client will also have access to your email address for account management purposes. The Ailuna for Business client will be an independent data controller of such personal data.
12 Data Retention
12.2 As an Ailuna user you have the right to delete your account at any time which will mean we will also delete the information associated with your account, but there may some limited circumstances where we retain account information, for example if necessary, in connection with a legal claim.
12.3 We retain information relating to our contracts for the lifetime of the contract and up to 7 years after.
12.4 Where we sought your consent to process your personal information and we have no other lawful basis to continue with that processing, if you subsequently withdraw your consent, we will delete your personal information.
12.5 If you request that we no longer send you direct marketing communications, we will keep a record of your request and contact details to ensure that your request is respected.
12.6 Where it is no longer necessary for us to keep personal information, it will be deleted or in some cases anonymised so that you cannot be identified from it.
13.1 Our terms and conditions state that you must not use Ailuna if you are under 13 years of age without the supervision and permission of a parent, guardian or teacher.
13.1.1 If the user is under the age of 13 then it is the responsibility of the parent, guardian or teacher to ensure that they do not submit any personal information to us about the user
13.2 In addition, our Products are not specifically aimed at young people but if you are a young person aged 13 or over, using our Products, then this policy will tell you about your rights and how we use your data. Please ask your parents or guardian if you have any questions and they can also Contact Us.
14 Your Choices
14.1 You have the right to ask for access to any personal information that we hold about you in our records, to correct any inaccuracies and to update any out-of-date information. In some circumstances, you have the right to request the erasure of your personal information or a restriction of its use.
14.2 You have the right to object to us processing your personal information in some cases. In particular, you can ask us to stop sending you direct marketing communications at any time (however please note that we may continue to send you service-related (i.e. non-marketing) communications, such as e-mail updates on how to live sustainably). If you wish to exercise any of these rights, please write to us at the address listed below.
14.3 You may unsubscribe from e-mail marketing communications at any time by e-mailing the address below in Contact Us or clicking on the “unsubscribe” link in any Ailuna marketing e-mails.
14.4 You have the right to complain about the way your data has been handled or processed.
14.4.1 If you have a concern about how we use your information, as a first step please use the details in Contact Us to inform us. We will investigate your concern, and respond to you in writing within a reasonable time setting out our proposed remedial action.
14.4.2 If you are not happy with the outcome, and you think we have processed your personal information in a manner which is unlawful or breaches your rights you also have the right to complain to a European Data Protection Authority in your place of residence or work, or the jurisdiction in which the processing took place.
15 Law and Jurisdiction
16 Contact Us