GDPR DATA Privacy notice
This
is the privacy notice of Hotflair Ltd.
We
respect your privacy and are determined to protect your personal data. The
purpose of this privacy notice is to inform you as to how we look after your
personal data when you visit our website (regardless of where you visit it
from). We’ll also tell you about your privacy rights and how the data
protection law protects you.
1.
WHO WE ARE AND IMPORTANT INFORMATION
What is the
purpose of this privacy notice?
This
privacy notice aims to give you information on how we collect and process your
personal data through your use of this website, including any data you may
provide through this website when you contact us or purchase goods online.
This
website is not intended for children and we do not knowingly collect data
relating to children.
You
must read this privacy notice together with any other privacy notice we may
provide on specific occasions when we are collecting or processing personal
data about you so that you are fully aware of how and why we are using your
data. This privacy notice supplements the other notices and is not intended to
override them.
Data
controller
Hotflair
Ltd is collectively referred to as "Hotflair Ltd", "we",
"us" or "our" in this privacy notice and is the controller
and responsible for your personal data. Our contact details are 6-8 Cornmarket,
Thame, OX9 3DX. For all data matters please contact
our data representative Sally Dickinson.
Third-party
links outside of our control
This
website may include links to third-party websites, plug-ins and applications.
Clicking on those links or enabling those connections may allow third parties
to collect or share data about you. We do not control these third-party
websites and are not responsible for their privacy statements.
2.
THE PERSONAL DATA WE COLLECT ABOUT YOU
Personal
data, or personal information, means any information about an individual from
which that person can be identified. You can find out more about personal data
from the Information
Commissioners Office.
We
may collect, use, store and transfer different kinds of personal data about you
as follows:
- When you visit our website, create an account with us
and use your account to buy products.
- When you purchase products in any of our shops or over
the phone.
- When you redeem
vouchers from What’s Cooking on the phone, in a shop or online.
- When you call our
customer care team or fill in a website contact form.
·
When
you engage with us on social media.
- When you have given a third party permission to share
information they hold about you with us.
- When you visit our shop which uses a CCTV systems that
may record your image.
We
do not collect any Special Categories of Personal Data about
you (this includes details about your race or ethnicity, religious or
philosophical beliefs, sex life, sexual orientation, political opinions, trade
union membership, information about your health and genetic and biometric
data). Nor do we collect any information about criminal convictions and
offences.
3.
HOW WE COLLECT YOUR PERSONAL DATA
We
collect, use, store and transfer different kinds of personal data and
information about you which you provide to us through:
·
The online forms on our website (including in relation to
contacting us or creating an account).
·
Buying a gift voucher or joining our marketing email list.
·
Ordering a product from our shop, in person, by telephone or by
email.
·
Making a complaint or raising queries.
·
In some locations we use CCTV to protect our customers,
premises, assets and staff from crime. We do this on the basis of our
legitimate business interests.
4.
HOW WE USE YOUR PERSONAL DATA
We
will only use your personal data when the law allows us to. Most commonly, we
will use your personal data in the following circumstances :
·
Performance of Contract this means processing your data
where it is necessary for the performance of a contract to which you are a
party, or to take steps at your request before entering into such a contract.
·
Legitimate Interest this means the interest of our business in conducting and
managing our business to enable us to give you the best service/product and the
most secure experience. We make sure we consider and balance any potential
impact on you (both positive and negative) and your rights before we process
your personal data for our legitimate interests. We do not use your personal
data for activities where our interests are overridden by the impact on you
(unless we have your consent or are otherwise required or permitted to by law).
·
Comply with a legal or regulatory obligation this
means processing your personal data where it is necessary for compliance with a
legal or regulatory obligation that we are subject to.
We
do not rely on consent as a legal basis for processing your personal data other
than in relation to sending third party direct marketing communications to you
via email. You have the right to withdraw consent to marketing at any time by
contacting our data representative Sally Dickinson.
5.
LEGAL BASIS FOR PROCESSING OUR CUSTOMERS’ PERSONAL DATA AND INFORMATION
·
It is necessary for the performance of a contract between us, for
the provision of services or goods, or in order to take steps at your request
prior to entering into a contract.
·
It is necessary for the purposes of the legitimate interests of
pursuing and developing our business, where such interests are not overridden
by your rights or interests.
·
It is necessary for us to comply with a legal requirement.
·
You have given your consent to the processing.
6.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
·
to assist with your enquiries.
·
to fulfil your order or to provide
services or facilities you request from us.
·
to administer and manage our
relationship with you.
·
to send you marketing information about
our goods and services which we feel might be of interest to you.
·
to keep a record of orders.
·
where required by law.
·
where necessary to protect your health
or wellbeing.
·
to scan and monitor electronic
communications sent to us (including attachments) for viruses or malicious
software, to process and encrypt personal data and information to protect and
manage email traffic and to store personal data and information on our systems
to pursue our legitimate interests including for document retention purposes.
·
such other actions as are necessary to
manage our activities and to enforce or defend our rights and interests.
7. MARKETING
We
strive to provide you with choices regarding certain personal data uses,
particularly around marketing and advertising.
Promotional
offers from us
We
may use your Identity, Contact, Technical, Usage and Profile Data to form a
view on what we think you may want or need, or what may be of interest to you.
This is how we decide which products, services and offers may be relevant for
you.
You
will receive marketing communications from us if you have requested information
from us or purchased goods or services from us, or if you provided us with your
details when you entered a competition or registered for a promotion and, in
each case, you have not opted out of receiving that marketing.
Third-party
marketing
We
will get your express opt-in consent before we share your personal data with
any company outside of Hotflair Ltd
Opting
out
You
can ask us or third parties to stop sending you marketing messages at any time by
following the opt-out links on any marketing message, or by contacting our data
representative Sally Dickinson.
Cookies
You
can set your browser to refuse all or some browser cookies, or to alert you
when websites set or access cookies. If you disable or refuse cookies, please
note that some parts of this website may become inaccessible or not function
properly. For more information about the cookies we use, please see our cookie
policy.
Change
of purpose
We
will only use your personal data for the purposes for which we collected it,
unless we reasonably consider that we need to use it for another reason and
that reason is compatible with the original purpose. If you wish to get an
explanation as to how the processing for the new purpose is compatible with the
original purpose, please contact our data representative Sally Dickinson.
If
we need to use your personal data for an unrelated purpose, we will notify you
and we will explain the legal basis which allows us to do so.
Please
note that we may process your personal data without your knowledge or consent,
in compliance with the above rules, where this is required or permitted by law.
8.
INTERNATIONAL TRANSFERS
We
do not transfer your personal data outside the European Economic Area.
9.
DATA SECURITY
We
have put in place appropriate security measures to prevent your personal data
from being accidentally lost, used or accessed in an unauthorised way, altered
or disclosed. In addition, we limit access to your personal data to those
employees, agents, contractors and other third parties who have a business need
to know. They will only process your personal data on our instructions and they
are subject to a duty of confidentiality.
We
have put in place procedures to deal with any suspected personal data breach
and will notify you and any applicable regulator of a breach where we are
legally required to do so.
10.
DATA RETENTION
We
will only retain your personal data for as long as necessary to fulfil the
purposes we collected it for, including for the purposes of satisfying any
legal, accounting, or reporting requirements.
By
law we have to keep basic information about our customers (including contact,
identity, financial and transaction data) for 6 years after they cease being
customers, for tax purposes.
In
some circumstances you can ask us to delete your data: see Your legal rights below
for further information.
In
some circumstances we may anonymise your personal data (so that it can no
longer be associated with you) for research or statistical purposes in which
case we may use this information indefinitely without further notice to you.
11.
YOUR LEGAL RIGHTS
Unless subject to an exemption under the data protection
laws, you have the following rights with respect to your personal data:
·
the
right to request a copy of the personal data which we hold about you.
·
the
right to request that we correct any personal data if it is found to be
inaccurate or out of date.
·
the
right to request your personal data is erased where it is no longer necessary
to retain such data.
·
the
right to withdraw your consent to the processing at any time, where consent was
the lawful basis for processing your data.
·
the
right to request that we provide you with your personal data and where
possible, to transmit that data directly to another data controller, (known as
the right to data portability), where applicable i.e. where our processing is
based on consent or is necessary for the performance of our contract with you
or where we process your data by automated means).
·
the
right, where there is a dispute in relation to the accuracy or processing of
your personal data, to request a restriction is placed on further processing.
·
the right to object to our processing of personal data, where
applicable i.e. where processing is based on our legitimate interests (or in
performance of a task in the public interest/exercise of official authority).
·
direct marketing or processing for the purposes of
scientific/historical research and statistics).
If
you wish to exercise any of the rights set out above, please contact
sally@whatscookingthame.co.uk
No fee
required – with some exceptions
You
will not have to pay a fee to access your personal data (or to exercise any of
the other rights). However, we may charge a reasonable admin fee if your
request is clearly unfounded, repetitive or excessive. Alternatively, we may
refuse to comply with your request in these circumstances.
What we may
need from you
We
may need to request specific information from you to help us confirm your
identity and ensure your right to access your personal data (or to exercise any
of your other rights). This is a security measure to ensure that personal data
is not disclosed to any person who has no right to receive it. We may also
contact you to ask you for further information in relation to your request to
speed up our response.
Time limit to
respond
We
try to respond to all legitimate requests within one month. Occasionally it may
take us longer than a month if your request is particularly complex or you have
made a number of requests. In this case, we will notify you and keep you
updated.
12. Changes to this notice and your duty to inform us of changes
This
version was updated on 29 April 2020.
Please
keep us informed if your personal data changes during your relationship with
us. It is important that the personal data we hold about you is accurate and
current.
13. Queries, requests or concerns
To
exercise all relevant rights, queries or complaints in relation to this policy
or any other data protection matter between you and us, please in the first
instance contact our data representative on sally@whatscookingthame.co.uk
If
this does not resolve your complaint to your satisfaction, you have the right
to lodge a complaint with the Information Commissioners Office .