1Who we are
GiftEasy is run by [company legal name], a company registered in [England and Wales] with number [company number]. Our registered office is [address]. We are registered with the Information Commissioner's Office under number [ICO registration number].
We are the controller of your personal data. That means we decide how and why it is used.
Questions or requests: [privacy contact email]. Our data protection officer (or privacy lead) is [DPO contact].
2The short version
- We use your data to run your lists, find gift ideas and send the reminders you ask for.
- We earn money when you buy through our shop links. Most networks get a click reference from us so they can tell us which click led to a sale. Amazon links carry only our store tag.
- Commission never changes which gift ideas we show you, or their order.
- People you buy for stay private. Only you see the profiles you create.
- If you're 13–17, we keep things extra private. Your suggestions aren't personalised unless you switch that on. No marketing, no public lists, and your data never feeds other people's suggestions or our supplier insights.
- Later, we plan to sell supplier insights: aggregated trends, each from a group of at least 50 people, never including anyone under 18. They contain no names, contact details or individual records. You can opt out.
- You can ask to see, download or delete your data.
3What we collect
3.1 Data you give us
| Type | Examples |
|---|---|
| Account | Name, email, phone number (for WhatsApp or sign-in codes), sign-in through Google or Apple, age band, country, language |
| Your age | Your date of birth or age band, which you tell us at sign-up |
| Lists and items | Wish lists, gift plans, items, notes, "this shop only", budgets |
| Occasions | Birthdays, anniversaries, Christmas and other dates, with budgets |
| People you buy for | Nicknames, age bands, interests, teams, sizes, any notes you add |
| Children's lists | If you are a parent managing a child's list: the child's nickname, age band, interests, sizes and wish-list items |
| Messages and inputs | What you type or say to the gift finder, voice notes, photos and screenshots you share to add items |
| Reservations | What you reserve or mark as bought for others |
| Group gifts | Your role (organiser or contributor) and amounts. Card details go straight to Stripe, never to us |
| Partner programme | If you are a partner: name, contact details, Stripe account status, promotion links, earnings and payouts |
| Preferences | Notification channel and types, marketing choices, privacy settings |
3.2 Data we collect when you use GiftEasy
| Type | Examples |
|---|---|
| Activity events | Items added, lists viewed, questions answered, gifts reserved |
| Clickouts | Each tap through to a shop: when, which item or card, which list, which market. Each clickout has an ID we pass to the shop's affiliate network |
| Commission | Whether a clickout led to a confirmed sale and the commission we earned |
| Referral | If you signed up through a partner's link, which partner |
| Device and log data | IP address, device type, app version, crash reports, cookies or similar tech (see section 10) |
3.3 Data from others
- Other users. Someone may create a private recipient profile about you, add you to a gift plan or invite you to view a list. See section 6.
- Affiliate networks. Awin, Impact, CJ, Skimlinks and Amazon Associates tell us whether a click led to a sale and the commission due. Amazon does not tell us who bought what.
- Sign-in providers. Google or Apple give us your name and email if you sign in with them.
- Stripe. Stripe tells us whether a partner or group-gift organiser has passed its checks, and the status of payments and payouts.
4How we use it, and our lawful bases (UK GDPR)
| Purpose | Data | Lawful basis |
|---|---|---|
| Run your account, lists, reservations and occasions | Account, lists, occasions, reservations | Contract |
| Gift ideas and personalised screens (18+) | Your lists, profiles you create, activity, answers | Contract (core service) |
| Gift ideas for 13–17s | Non-personalised by default. If you switch personalisation on: your lists, activity, answers. Gift plans for others work as normal | Consent, for personalisation you switch on. |
| A parent's list for their under-13 child | What the parent enters: nickname, age band, interests, sizes, items | |
| Learn from many users to improve ideas ("people like you also wished for") | Activity of users aged 18+, de-identified | Legitimate interests (better suggestions). 13–17 data never used |
| Add items from links, photos and voice | Inputs, item links | Contract |
| Fetch product details from a shop page you added | The link you added | Legitimate interests (show you the item) |
| Send reminders and list updates you asked for | Occasions, list activity, channel details | Contract |
| Send marketing (gift ideas, price drops, card nudges) | Contact details, preferences | Consent. Never sent to 13–17s |
| Track clickouts and earn commission | Clickouts, commission | Legitimate interests (funding a free service) |
| Run the partner programme | Partner data. Referral link on referred users | Contract (partners). Legitimate interests (referred users) |
| Pay partners and stop fraud | Partner data, Stripe status | Contract. Legal obligation (tax, anti-fraud) |
| Group gifts | Roles, amounts, Stripe status | Contract |
| Supplier insights (later) | Aggregated activity of users aged 18+ | Legitimate interests. You can opt out. |
| Security, fraud prevention, abuse | Logs, device data | Legitimate interests. Legal obligation |
| Legal claims and compliance | Any relevant data | Legal obligation. Legitimate interests |
Where we rely on legitimate interests, we have balanced our interests against yours. You can ask us for that assessment and you can object (section 9).
Sensitive data. We don't ask for health, religion or similar details. Please don't put them in notes or recipient profiles. If you do, we use them only to give you gift ideas.
Automated decisions. We use AI to suggest gifts and lay out your screens. None of this has a legal or similarly significant effect on you.
5Gift ideas and AI
- We use AI models to understand what you tell us, suggest gifts, write suggested card messages, and pull product details from shop pages.
- We send the text, photos or voice notes you give us to our AI providers to do this. They act on our instructions as processors.
- Commission never changes what we suggest. It doesn't affect which gift ideas we show or how we rank them. If the same item is cheaper at another shop, we show the cheaper shop first.
- AI can get things wrong. Check prices and details on the shop's site before you buy.
6People you buy for, and people who haven't joined
- When you create a profile for someone you buy for, only you can see it. We keep it minimal: nickname, age band, interests, sizes.
- We don't hold their contact details unless you send them an invite.
- We use these profiles to suggest gifts for you.
- If you're the person in a profile and you'd like to know what we hold, or want it deleted, contact [privacy contact email]. We'll help where we can identify the profile.
- If that person joins GiftEasy and links to you, their own wish list replaces your guesses.
8International transfers
Some providers are in the United States or elsewhere outside the UK. When we transfer data, we use the UK–US data bridge (for certified US companies), the ICO's International Data Transfer Agreement or Addendum, or another lawful safeguard. Ask us for a copy.
9Your rights
You have the right to:
- see the data we hold about you, and get a copy;
- correct it;
- delete it;
- restrict or object to our use of it, including objecting to supplier insights and to any marketing;
- take it to another service (portability);
- withdraw consent at any time, for example by turning off marketing in settings.
You can always email [privacy contact email]. We reply within one month.
If you're unhappy, please tell us first. You can also complain to the Information Commissioner's Office: https://ico.org.uk/make-a-complaint/ or 0303 123 1113.
11How long we keep data
| Data | Kept for |
|---|---|
| Account, lists, occasions | While your account is open, then [period] |
| Photos, screenshots, voice notes | [period] after extraction |
| Activity events | [period], then aggregated or deleted |
| Clickouts and commission | [period] (needed for network queries and accounts) |
| Partner and payout records | [period] (tax records) |
| Recipient profiles | Until you delete them or close your account |
| Price and stock fetched from shop pages | 24 hours. Titles and descriptions 30 days |
12Children and teenagers
- You must be 13 or over to have an account. If we learn that someone under 13 has an account, we will delete it.
- Under-13s can have a wish list only through a parent's account. The parent controls it. The child does not sign in.
- If you're 13–17, we set things to extra private:
- no marketing messages, including price drops;
- no public lists;
- your suggestions aren't personalised unless you switch that on (we explain what it means first);
- your data never helps make other people's suggestions;
- your data never goes into supplier insights;
- you can't be a partner;
- you join group gifts only through a parent.
13Marketing
- We send marketing (gift ideas, price drops, card nudges) only if you opt in, and never to anyone aged 13–17.
- Reminders you set up contain only the occasion, the date and a link. We send them because you asked.
- You can opt out at any time in settings, or by replying STOP on WhatsApp or using the unsubscribe link in emails.
13AWaitlist
Before launch, you can leave your email on the website to hear when sign-ups open.
- What we collect: your email address, whether you came to start a wish list or find a gift, the person you picked ("Mum", "Dad" and so on) if you picked one, your market (UK or US, from your country), the version of the sign-up wording you saw, and a salted hash of your IP address. We use the hash only to stop abuse. We do not store your IP address.
- Why: to send you launch news. Nothing else.
- Lawful basis: consent.
- How long we keep it: we delete waitlist data 12 months after launch, or sooner if you ask.
- Unsubscribe: every email has an unsubscribe link. You can also ask us to delete your email at any time.
14Security
We protect data with encryption in transit, access controls and monitoring. No system is perfect. If a breach puts you at high risk, we'll tell you.
15Changes
If we make important changes, we'll tell you in the app or by email before they take effect.
US privacy notice (including California)
This section applies to US residents.
Categories we collect (last 12 months)
| CCPA category | Examples | Source | Purpose | Disclosed to |
|---|---|---|---|---|
| Identifiers | Name, email, phone, account ID, IP address | You, your device | Run the service, security | Processors, Stripe, sign-in providers |
| Customer records | Payout details (partners), via Stripe | You, Stripe | Payouts | Stripe |
| Characteristics of protected classes | Age band | You | Age rules | Processors |
| Commercial information | Lists, reservations, clickouts, confirmed commission | You, networks | Service, revenue | Processors, networks (click ID only; Amazon gets only our store tag) |
| Internet activity | Events, device and log data | Your device | Service, security, improvement | Processors |
| Audio and visual | Voice notes, photos, screenshots | You | Add items | AI processors |
| Inferences | Gift interests and preferences | Derived | Gift ideas | Processors |
"Sale" and "sharing"
- We do not sell personal information. Supplier insights are deidentified aggregates (below).
- We do not "share" it for cross-context behavioural advertising.
- When you tap through to a shop on Awin, Impact, CJ or Skimlinks, the network receives a click ID so we can be paid. Amazon receives only our store tag.
- Supplier insights will be deidentified aggregates. We will publicly commit not to re-identify them, and we will contractually bar suppliers from trying.
Your rights
You can:
- know what we collect, use and disclose;
- access it and get a copy;
- correct it;
- delete it;
- opt out of sale or sharing;
- limit the use of sensitive personal information (we only use it as permitted);
- not be discriminated against for using these rights.
Submit a request at [privacy contact email] or [web form]. We will verify your identity. An authorised agent can make a request for you.
Retention
See section 11.
Other states
Residents of other states with privacy laws (for example Virginia, Colorado, Connecticut, Texas, Oregon) have similar rights to access, correct, delete and opt out. Use the same contact. If we refuse, you can appeal by replying to our decision.
Children (COPPA)
We do not knowingly collect personal information from children under 13. Under-13 lists are created and managed by a parent. The child does not use an account. If you believe we have collected data from a child under 13, contact us and we will delete it.
Do Not Track
We do not respond to browser Do Not Track signals.
Questions about this page?
Contact GiftEasy