1. Definitions

Merchant: A physical establishment or brand with which you interact when making purchases.

2. Scope of Data Collection

We do not collect any personal data beyond what you voluntarily provide to us.

When you enter payment information (such as a payment card number), Sticky facilitates the seamless use of this information across multiple Merchants on a case-by-case basis at the moment you interact with a new Merchant. This payment information remains encrypted and cannot be accessed by Sticky or any participating Merchant.

3. Data Usage and Sharing

We do not sell your personal data. However, certain personal details (such as your name and email address) may be made available to other Merchants to streamline transactions. This occurs on a case-by-case basis and only at the moment you interact with a new Merchant.

• Personal data is accessible only to Sticky and the Merchant with which you are currently engaging.
• No personal data is shared with Merchants you have not interacted with.

4. Marketing and Consent

Merchants are strictly prohibited from using your personal data for marketing purposes unless you have explicitly provided consent. Consent is never assumed and must be actively granted.

The only permissible automatic transfer of personal data between Merchants, on a case-by-case basis, is for the purpose of facilitating seamless payment experiences. For example, sharing your email address with a new Merchant enables you to receive payment receipts without the need to re-enter your information repeatedly.

5. Data Controllers and Responsibilities

• If you interact only with [Name of merchant], the data controllers responsible for your personal data are [Name of merchant] and Sticky.
• If you engage with an additional Merchant through Sticky, that Merchant also becomes a data controller with respect to your personal data.
• Each Merchant is independently responsible for its own compliance with data protection laws. Sticky is not responsible for how Merchants use your personal data beyond its intended purpose.

6. Consent Management and Limitations

Merchants may receive personal data from multiple sources outside of Sticky. While we can document and enforce the consent preferences you establish within our platform, we cannot track or modify any changes made directly with a Merchant.

For example, if you opt in to receive marketing communications from a Merchant via Sticky but later revoke consent directly with that Merchant, Sticky will not have visibility into or be able to reflect that change. You must manage such updates directly with the Merchant in question.

7. User Rights and Automated Privacy Controls

7.1 Right to Be Forgotten (Data Deletion)

We provide a one-button-press "Right to Be Forgotten" feature, allowing you to permanently delete all personal data associated with your account. This deletion is immediate and irreversible, ensuring that all stored information is removed from our systems and cannot be recovered.

7.2 Automated Subject Access Request (SAR) - GDPR Compliance

Users can initiate an automated Subject Access Request (SAR) at any time through our platform to obtain a comprehensive report of all personal data stored by Sticky. This self-service process ensures full transparency regarding the information we hold about you, in compliance with the General Data Protection Regulation (GDPR).

8. Cross-Border Data Transfers

As a global platform, we may store and process certain users' personal data outside the UK or the European Economic Area (EEA). If such transfers occur, we ensure that your data is processed:

• In jurisdictions that provide an adequate level of data protection, as determined by applicable regulations, or
• In compliance with legally recognized safeguards such as standard contractual clauses (SCCs) or binding corporate rules (BCRs) to ensure the continued protection of your data.

9. Contact and Further Information

If you have any questions regarding how your personal data is handled, wish to exercise your data rights, or need assistance with data deletion or access requests, please contact us.