Privacy Statement "Be More super"
Effective Date: 22nd of June 2021.
When you make use of the “Be More Super” mobile app (hereinafter referred to as the “App”), United Supermarkets LLC (hereinafter referred to as “United Supermarkets,” “we,” “us” or “our”) will collect and use personal data directly from you when you provide it to us and automatically when you use the App. We aim to carefully and safely use your personal data in line with applicable privacy rules and regulations.
This Privacy Statement explains our policies and procedures regarding information we collect from you and the App, including who we are, what personal data we collect, how and for which purposes we process your personal data, how you can exercise your privacy rights and all other information that may be relevant to you. We also have a special section for parents and legal guardians of minors under the age of 13 who may use the App.
Finally, we would like to point out that we are continually developing and improving the App. If this changes the way we process your personal data, we will inform you through this Privacy Statement. We therefore recommend you to regularly take notice of the Privacy Statement for any modifications.
Who are we?
We, United Supermarkets, are the data controller of the App and therefore responsible for processing your personal data within the App. We are located at 7830 Orlando Ave., Lubbock Texas 70423. If you want to contact us, please use the contact details provided at the bottom of this Privacy Statement.
When using the App, we use third party service providers to process personal data on our behalf.
Which personal data do we collect from you?
The following personal data is collected in order to use the App:
- Email address
- Date of birth
- Device usage data
A DeviceID and a Firebase Cloud Identifier for sending of push notifications
- Game behavior
Such as your personal avatar, collected cards and recipes.
- Cards sharing data
If you choose to trade cards; to connect both players for a trade request, a randomly generated unique code from both players is shared to connect.
- Survey data
If you chose to participate in a survey; contact details (email address or telephone number) and feedback on impact of the loyalty programme. Surveys will not be offered to children under 13 years of age.
- Questions and complaints
If you choose to reach out to us, we might process your email address and your question or complaint to determine how to provide support.
For which purposes do we process your personal data?
We collect and process your personal data to provide you with the App and its content, and any other information, products, or services that you may request from us; to fulfill any other purpose for which you provide it, such as account creation; collection of cards, to notify you when App updates are available. We may also disclose personal data if required by law or legal process, such as to comply with any court order or subpoena or to respond to any government or regulatory request; if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of United Supermarkets, our customers or others, including to: protect the safety of a child; protect the safety and security of the App or enable us to take precautions against liability; to law enforcement agencies or for an investigation related to public safety.
We use device usage data to send push-notifications with helpful information, such as trade requests, card balance or with a request to participate in a survey.
In addition, we use the data in a pseudonymous or anonymous form to understand how we can develop and improve the service, as well as for reporting purposes, statistical, and analytical purposes. When necessary we process personal data to fulfill a legal obligation.
On what legal ground do we base the processing of your personal data?
We base the processing of your personal data within the App on several legal grounds:
Performance of a contract. If you download, install and use the App you agree to the terms and conditions and therefore you enter into a binding agreement with us. We use your personal data for processing necessary for performance of the service contract with you, i.e. the services associated with the digital cards collection. For children under 13 years, we only process your personal data after your parent’s or legal guardian’s consent.
Consent. You may freely and based on specific information provided – e.g. in this Privacy Statement – choose to download and use the app, provide your email address, participate in a survey and receive helpful push notifications. When you choose to use these options, you thereby consent to the processing of data for such purposes by us. Note that you can always withdraw your given consent. Under the headline ‘Can you withdraw you given consent later on?’ you can read how to do so.
For compliance with a legal obligation. We may process personal transactional data when necessary to comply with tax, fiscal and other legal obligations.
For the legitimate interest pursued by us. The processing of your personal data is necessary to understand how we can develop and improve the service, as well as for reporting purposes, general statistical and analytical purposes. Processing personal data for these purposes serves a legitimate business interest of us and has no or limited impact on the data subject’s privacy, because data is used in a pseudonymous or anonymous form when possible.
This section of our Privacy Statement is applicable when the collection of personal data involves minors under the age of 13. The Children’s Online Privacy Protection Act of 1998 and its rules (collectively, “COPPA”) require us to inform parents and legal guardians (“parents”) about our practices for collecting, using, and disclosing personal data from children under the age of 13 (“children”). It also requires us to obtain verifiable consent from a child’s parent for certain collection, use, and disclosure of the child’s personal data.
This section notifies parents of: the types of data we may collect from children; how we use the data we collect; our practices for disclosing that data; our practices for notifying and obtaining parents’ consent when we collect personal data from children, including how a parent may revoke consent; and the third party service providers that collect or maintain data from children through the App.
Personal data we collect from children
If children use the App, some personal data collection is necessary in order to access and use content and features. If such personal data is not provided, they cannot use the App. Where optional, such as with receiving of push notifications the child is free to provide consent or to refrain from using this feature.
We only collect as much data about a child as is reasonably necessary for the child to participate in an activity, and we do not condition his or her participation on the disclosure of more personal data than is reasonably necessary.
Personal data we collect
Children must provide us with the following personal data to use and engage with the App: date of birth; parent’s email address; their own email address and password. Device usage data and game behavior is collected indirectly, through use of the App.
We will randomly generate a username and children are required to choose an avatar.
How we use children’s personal data
We collect and process children’s personal data to provide them with the App and its content, and any other information, products, or services that they may request from us; to fulfil any other purpose for which personal data is provided, such as account creation; and to notify children when App updates are available. We may also disclose personal data if required by law or legal process, such as to comply with any court order or subpoena or to respond to any government or regulatory request; if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of United Supermarkets , our customers or others, including to: protect the safety of a child; protect the safety and security of the App or enable us to take precautions against liability; to law enforcement agencies or for an investigation related to public safety.
We use device data to send push-notifications with helpful information, such as trade requests or card balance.
Accessing and correcting children’s personal data
At any time, parents may review their child’s personal data maintained by us, require us to correct or delete the personal data, and/or refuse to permit us from further collecting or using their child’s data.
Parents can review, change, or delete their child’s personal data by: logging into your child’s account and visiting his or her account settings page OR sending us an email at firstname.lastname@example.org OR you may delete your child’s account through the account settings in the App.
To protect your privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we provide any information or make corrections.
To whom do we provide your personal data?
We use third party service providers to process, on our behalf, the personal data collected through the App, including Brand Loyalty USA Inc., Kaplite LTD (Fantom), Google, and Piwik PRO. Your personal data is used for internal purposes only, to support and improve the App. We take full responsibility for third party service providers performance when processing your personal data. We ensure that they maintain an appropriate level of data protection.
For any questions or concerns regarding our privacy policies and use of children’s information through our App, please contact us via the contact details below.
Is your personal data being transferred outside the country where you are located?
In principle your personal data is not being transferred outside the United States. We may only transfer your personal data to the European Union, as this is necessary for providing our services to you. We have taken all necessary measures to secure that the transfers take place within the limits set by law.
How long do we store your personal data?
Your personal data will be removed or made anonymous when your personal data is no longer necessary for the purposes for which these personal data are processed.
How can you exercise your privacy rights?
At every desired moment you may request to access, rectify or erase your personal data.
In addition to this, you may in certain cases also have the right of restriction of processing concerning your personal data, the right to object to processing as well as the right to data portability.
To invoke your privacy rights, please contact us by using the contact details at the bottom of this Privacy Statement OR you may delete your account through the account settings in the App. Please keep in mind that we may ask for additional information to verify your identity.
Can you withdraw your consent?
If you no longer want to use the App or have it collect usage data, or to have your personal identifier stored within the Application, you may remove your account through the settings in the App. If you want to withdraw your consent, please contact us via the contact details at the bottom of this Privacy Statement.
In addition, you can manage your push notification preferences or deactivate the push notification feature at any time by turning off the notification setting in the App or in the device setting of your device.
Please keep in mind that withdrawal does not have retrospective effect and the withdrawal of your consent is only possible in case you first have given your consent.
Are you obliged to provide your personal data to us and what are the consequences if you do not?
If you choose to use the App some personal data collection is necessary, which means that you cannot use the App without providing this data. Where optional, such as with receipt of push notifications, or participation in surveys, you are free to provide consent or to refrain from using this feature.
Do we use profiling techniques or make automated decisions?
We do not use profiling techniques and/or any kind of automated decision-making.
Which cookies do we use?
Within the App only functional and analytical cookies will be used. Functional cookies are necessary for a proper functioning of the App. For example, a functional cookie makes sure you do not have to login on every separate page you visit and keeps track of the amount of collected cards. Analytical cookies help us to improve the App, including allowing us to count App visitors and see how visitors make use of the App.
How do we safeguard your data?
We have implemented measures designed to secure your personal data from accidental loss and from unauthorized access, use, alteration, and disclosure.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal data transmitted through our App. Any transmission of personal data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.
How can you contact us?
If you have any questions about the way we process your personal data, please read this Privacy Statement first. For additional questions or if you want to contact us, please
Mary Myers, Manager of Digital Engagement
To contract our Privacy Officer (DPO):
Shannon Miller, Privacy Officer