Last Updated: June 23, 2022
Welcome to Blank Street.
Blank Street, . (“us”, “we”, or “our”) operates in the USA as Blank Street Inc, in the UK as Blank Street UK Limited, on our website at www.blankstreet.com and the Blank Street mobile application (hereinafter referred to as “Service”).
Our Privacy Policy governs your visit to www.blankstreet.com and Blank Street mobile application, and explains how we collect, safeguard and disclose personal information that results from your use of our Service.
We use your data to provide and improve our Service. By using this Service, you agree to the collection and use of your personal information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms of Service.
Our Terms of Service (“Terms”) govern all use of our Service and together with the Privacy Policy constitutes your agreement with us (“agreement”).
APP means our Blank Street mobile application.
SERVICE means the www.blankstreet.com website and Blank Street mobile application operated by Blank Street, Inc.
PERSONAL DATA / PERSONAL INFORMATION means data about a living individual which can directly or indirectly identify them (or from those and other information either in our possession or likely to come into our possession).
USAGE DATA is data collected automatically either generated by the use of Service or from Service infrastructure itself (for example, the duration of a page visit).COOKIES are small files stored on your device (computer or mobile device).
DATA CONTROLLER means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.
DATA PROCESSORS (OR SERVICE PROVIDERS) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
DATA SUBJECT is any living individual who is the subject of Personal Data.
THE USER is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.
Personal Data While using our Service, we may ask you to provide us with Personal Data that can be used to contact or identify you. Personal Data may include, but is not limited to:
a) Email address b) First name and last name c) Phone number d) Address, State, Province, ZIP/Postal code, City e) Your Location (where you are making an order) f) Cookies and Usage Data g) Order records: products ordered, time and date of purchase and store/delivery location: where you are making an order through our App, or where you are making an order in store and you have signed up to our loyalty program and are also a registered App user h) Loyalty program data i) Limited credit card details (last 4 digits of Primary Account Number, expiry date, name registered to card, ZIP/postcode and card issuer)
Where you have opted in and subscribed, we may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out and/or unsubscribe from receiving any, or all, of these communications from us by following the unsubscribe link or by emailing at hey@blankstreet.com.
Usage Data
We may also collect information that your browser sends whenever you visit our Service or when you access Service by or through a mobile device (“Usage Data”).
This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access our Service through our App , this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
Location Data
We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service and to improve and customize our Serivce. In particular we collect and use Location Data to enable us (a) to fulfil delivery orders, and (b) to calculate proximity to stores in order to anticipate order volumes and to streamline our ordering process.
You can enable or disable location services when you use our Service at any time by way of your device settings.
Cookies Data For more information on the cookies data that we collect, please refer to our Cookies Policy.
Blank Street, Inc. uses the collected data for various purposes: a) to provide and maintain our Service; b) to notify you about changes to our Service; c) to allow you to participate in interactive features of our Service when you choose to do so; d) to provide customer support; e) to gather analysis or valuable information so that we can improve our Service; f) to monitor the usage of our Service; g) to detect, prevent and address technical issues; h) to fulfill any other purpose for which you provide it; i) to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection; j) to provide you with notices about your account and/or subscription, including expiration and renewal notices, email-instructions, etc.; k) to provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information; l) to include you in our loyalty program; m) in any other way we may describe when you provide the information; n) for any other purpose with your consent.
Blank Street, Inc. uses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimise and serve ads based on your past visits to our Service. For more information please see the table below in the section headed Third Party Service Providers.
In addition, we collect and/or generate anonymised and aggregated information from your use of the App. We use anonymised and aggregated information in various ways, including to understand App engagement and usage. Anonymised or aggregated information is not Personal Information.
We will retain your Personal Data only for as long as your use the Service and for 3 years following your deletion of the App to enable us to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods. When it is no longer necessary to retain your Personal Data, we will delete it from our systems (either by erasing or anonymising that data). After that time, we may retain aggregated data (from which you cannot be identified) and retain it for analytical and statistical purposes.
In relation to data retention practices for the UK, please refer to section 9 below.
Your Personal Information, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
If you are located outside United States and choose to provide your Personal Information to us, please note that we transfer the data, including Personal Data, to United States and process it there. We want to make sure that your Personal Data is transferred in a way which is secure. We will therefore only transfer data where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, for example:
a) by transferring your data to a country where there has been a finding of adequacy under applicable data protection legislation by the European Commission; b) by way of an intra-group agreement between Blank St entities, incorporating the standard contractual clauses for the transfer of Personal Data to jurisdictions without adequate data protection laws; c) by way of a data transfer agreement with a third party, incorporating the standard contractual clauses adopted or approved under applicable data protection laws for the transfer of Personal Data to jurisdictions without adequate data protection laws; d) We will take all reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy.
We may disclose Personal Information that we collect, or you provide:
a) Disclosure required by law.
Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities. b) Business Transaction. If we or our subsidiaries are involved in a merger, acquisition or asset sale, your Personal Data may be transferred or deemed transferred to our new owner(s).
Unfortunately, the transmission of information via the internet is not completely secure. Although we will apply our normal procedures and comply with legal requirements to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to us and any transmission is at your own risk.
We may amend this Privacy Policy from time to time by posting an updated version on our website.
How we use your Personal Data in compliance with the GDPR:
Purpose/Activity
To process your order (online and in store) (a) Manage payments, fees and charges (b) Collect and recover money owed to us
Type of data collected: (a) Identity (b) Contact (c) Financial (d) Transaction
Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) To fulfill your online order
Type of data collected: Location data
Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you(b) Necessary for our legitimate interests (to anticipate order volume and streamline ordering processes) To manage our relationship with you, which will include notifying you about changes to our terms or privacy policy
Type of data collected: (a) Identity (b) Contact (c) Profile (d) Marketing and Communications
Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you (b) Necessary to comply with a legal obligation(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) To enable you to partake in a prize draw, competition or complete a survey
Type of data collected: (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications
Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) To administer and protect our business, our App, and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Type of data collected: (a) Identity (b) Contact (c) Technical
Lawful basis for processing including basis of legitimate interest: (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)(b) Necessary to comply with a legal obligation To deliver relevant website content; to deliver advertisements and/or direct marketing to you, in accordance with your consent (where consent is required); to measure or understand the effectiveness of the advertising we serve to you; to maintain a suppression list where you have opted-out of marketing communications
Type of data collected: (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical
Lawful basis for processing including basis of legitimate interest: (a) Consent (in respect of delivery or marketing or advertising to you, for which your consent is legally required)(b) Necessary for our legitimate interests (to study how customers use our products/services and to develop them; to grow our business and to inform our marketing strategy) To use data analytics to improve our website, app, products/services, marketing, customer relationships and experiences
Type of data collected: (a) Identity (b) Usage
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) To make suggestions and recommendations to you about goods or services that may be of interest to you, where your consent is not legally required to receive those suggestions and recommendations
Type of data collected: (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to develop our products/services and grow our business) in circumstances in which your consent is not legally required, and you have not unsubscribed from the relevant communications To add you to our loyalty programme where you consent to join
Type of data collected: (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications
Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) To register you as a new customer (including by automated means)
Type of data collected: (a) Identity (b) Contact
Lawful basis for processing including basis of legitimate interest: Performance of a contract with you Please refer to our Data Retention Policy for further information on how long your Personal Data is retained for.
Your Rights
You have a number of rights in relation to your Personal Information under data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your Personal Information. Subject to certain exceptions, we will respond to you within 1 month from either: • the date that we have confirmed your identity; or • where we do not need to do this because we already have this information, from the date we received your request.
These rights include:
a) Right to access your Personal Information: You have the right to request a copy of the Personal Information that we hold about you, and request us to modify, update or delete such information. However, you should be aware that where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so. You can also access much of your Personal Information by logging into the App.
b) Right to object to, and/or restrict, processing: You have the right to object to, or restrict our processing of, your Personal Information in certain circumstances. We will stop such processing unless we can demonstrate compelling legitimate grounds for the processing which overrides your interests or if the processing is necessary for the establishment, exercise or defence of legal claims. You can also restrict or limit much of your information by logging into the App and disabling some or all App functionalities.
c) Right to erasure: You have the right to request that we erase your Personal Information in certain circumstances. We would only be entitled to refuse to comply with your request for erasure in limited circumstances and we will always tell you our reason for doing so. When complying with a valid request for the erasure of data we will take all reasonably practicable steps to delete the relevant data.
d) Right to rectification: You have the right to request that we rectify any inaccurate or incomplete Personal Information that we hold about you. You can also rectify certain of your Personal Information by logging into the App.
e) Right of data portability: You have the right to transfer your Personal Information between service providers where we rely on your consent or the performance of your contract as the lawful basis to use that information.
f) Right not to be subject to automated decision making: You have the right not to be subject to a decision based solely on automated processing including profiling which produces legal effects on you or similarly affects you.
g) Right to withdraw consent: Where we have obtained your consent to process your Personal Information for certain activities, you may withdraw this consent at any time by contacting us on the details in the ‘Contact Us’ section below.
h) Right to complain: You also have the right to lodge a complaint and can contact us using the details below in the ‘Contact Us’ section. You also have the right to make a complaint to the UK supervisory authority, the Information Commissioner’s Office (www.ico.org.uk).
CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require a person or company in the United States (and conceivable the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy. – See more at: https://consumercal.org/about-cfc/cfc-education-foundation/california-online-privacy-protection-act-caloppa-3/
According to CalOPPA we agree to the following: a) users can visit our site anonymously; b) our Privacy Policy link includes the word “Privacy”, and can easily be found on the page specified above on the home page of our website; c) users will be notified of any privacy policy changes on our Privacy Policy Page; d) users are able to change their Personal Information by emailing us at hey@blankstreet.com.
Our Policy on “Do Not Track” Signals:
We honor Do Not Track signals and do not track, plant cookies, or use advertising when a Do Not Track browser mechanism is in place. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
If you are a California resident, you are entitled to learn what data we collect about you, ask to delete your data and not to sell (share) it. To exercise your data protection rights, you can make certain requests and ask us:
What Personal Information we have about you. If you make this request, we will return to you: a) The categories of Personal Information we have collected about you. b) The categories of sources from which we collect your Personal Information. c) The business or commercial purpose for collecting or selling your Personal Information. d) The categories of third parties with whom we share Personal Information. e) The specific pieces of Personal Information we have collected about you. f) A list of categories of Personal Information that we have sold, along with the category of any other company we sold it to. If we have not sold your Personal Information, we will inform you of that fact. g) A list of categories of Personal Information that we have disclosed for a business purpose, along with the category of any other company we shared it with.
Please note, you are entitled to ask us to provide you with this information up to two times in a rolling twelve-month period. When you make this request, the information provided may be limited to the Personal Information we collected about you in the previous 12 months.
To delete your Personal Information. If you make this request, we will delete the Personal Information we hold about you as of the date of your request from our records and direct any service providers to do the same. In some cases, deletion may be accomplished through de-identification of the information. If you choose to delete your Personal Information, you may not be able to use certain functions that require your Personal Information to operate.
To stop selling your Personal Information. We do not sell your Personal Information for monetary consideration. However, under some circumstances, a transfer of Personal Information to a third party, or within our family of companies, without monetary consideration may be considered a “sale” under California law.
If you submit a request to stop selling your Personal Information, we will stop making such transfers. If you are a California resident, to opt-out of the sale of your Personal Information, click “Do Not Sell My Personal Information” at the bottom of our home page to submit your request.
Please note, if you ask us to delete or stop selling your data, it may impact your experience with us, and you may not be able to participate in certain programs or membership services which require the usage of your Personal Information to function. But in no circumstances, we will discriminate against you for exercising your rights.
To exercise your California data protection rights described above, please send your request(s) by one of the following means: By email: hey@blankstreet.com
Your data protection rights, described above, are covered by the CCPA, short for the California Consumer Privacy Act. To find out more, visit the official California Legislative Information website. The CCPA took effect on 01/01/2020.
We may share your Personal Information with any of the following groups of third parties, and for the following reasons and will always only do so in accordance with applicable data protection rules: a) Any other Blank St entities: we may share your Personal Information with any of our Blank St entities. b) Tax, audit, or other authorities: we may share your Personal Information with tax, audit or other authorities. c) Third party analytics providers: we may share your Personal Information with third party analytics providers who help us understand how our users use and engage with the App. d) Comply with law or protect our rights: we may share your Personal Information with third parties to comply with legal or regulatory requirements (for example, for age verification purposes), or if we have to enforce or apply our Terms or any other agreements or to protect our rights, property or our consumers, etc. e) Third party payment providers: we may provide paid products and/or services within our Service. In that case, we use third-party services for payment processing (e.g. payment processors). We will not store or collect your payment card details, although in order to identify card purchases in response to customer queries concerning orders we can obtain access to the last digits of the primary account number, the expiry date, the name registered to the card and the card issuer (e.g. Mastercard, Visa etc.). The full credit card information is provided directly to our third-party payment processors whose use of your Personal Information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information. f) Third party service providers: we may share your Personal Information with third party service providers and professional advisors, who facilitate our Service, perform Service-related activities or assist us in analysing how our Service is used, whose details are listed below.
Third Party Service Provider and Associated Service
Google - Analytics Firebase - Analytics MixpanelAnalytics GitHub - CI/CD Tools Google Ads - Behavioral Remarketing Facebook - Behavioral Remarketing Apple Store In-App Payments - Payment Processor Google Play In-App - PaymentsPayment Processor Segment - Analytics Sendgrid - Email Communications Juno - Analytics Square - Payment Processor Braze - Customer Engagement Platform AWS - Cloud service provider Mode Analytics - Analytics Fivetran - Analytics Twilio - Phone Communications Avenue - Analytics Sentry - Performance Monitoring For more information on our how our third party service providers collect and process your data, please refer to the privacy policies on their individual websites.
Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Our Services are not intended for use by children under the age of 13 (“Children”).
We do not knowingly collect personally identifiable information from Children under 13. If you become aware that a Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update “effective date” at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
If you have any questions about this Privacy Policy, please contact us: By email: hey@blankstreet.com.