Kneadthis ltd

Privacy Policy

BACKGROUND:

This Policy applies as between you, the User of this Web Site and Knead This LTD the owner and provider of this Web Site. This Policy applies to our use of any and all Data collected by us in relation to your use of the Web Site and any Services or Systems therein.

1. TC ” Important information and who we are”

1.1  Our website is not intended for children and we do not knowingly collect data relating to children. 

1.2  This Privacy Policy supplements the other policies (including our terms of use (Terms) and is not intended to override them.  

1.3  Knead This LTD is the controller and responsible for your personal data (we, us or our). 

1.4   To assist you further in understanding this Privacy Policy, we have set  out in Part 5 of Schedule 1 a glossary of terms used, examples of types  of personal data we collect, how we use it, the lawful basis for  processing such data and further details of your rights.  

1.5  We have appointed a data privacy manager (DPM).  If you have any questions about this Privacy Policy, including any  requests to exercise your legal rights, please contact our DPM in  writing, either: 

1.6  By email to: [email protected]

1.7  By post to:

       Knead This LTD

       71-75 Shelton Street

       London

       WC2H 9JQ

1.8  You have the right to make a complaint at any time to the ICO (www.ico.org.uk).  We would, however, appreciate the chance to deal with your concerns  before you approach the ICO so please contact us in the first instance.  

1.9   It is important that the data we hold about you is accurate and  current, therefore please keep us informed of any changes to your  personal data.

1.10   Our website may include links to third-party websites, plug-ins and  applications. By clicking on these links or enabling connections you may  be allowing third parties to collect or share your personal data. We  have no control these third-party websites, plug in or applications and  are not responsible for their privacy policies, therefore you should  also read their privacy policy to understand what personal data they  collect about you and how they use it.

2. TC “2. The data we collect about you”

2.1  We may collect, use, store and transfer the types of personal data about you listed in Part 1 of Schedule 1.

2.2   We also collect, use and share aggregated data. However, if we combine  aggregated data with your personal data so that it can directly or  indirectly identify you, we treat this as your personal data.

2.3  We do not collect any special categories of personal data [or any information about criminal convictions and offences].

2.4   If we are required by law, or under the terms of a contract we have  with you, to collect your personal data and you fail to provide it, we  may not be able to enter into perform the contract with you and, we may  have to cancel a product or service. We will notify you of this at the  relevant time.

3. TC “3. How is your personal data collected?”

We collect personal data in the following ways:

DIRECT INTERACTIONS

You  may provide personal data when you complete online forms, request  products/services, subscribe to our services, create a user account, or  otherwise or correspond with us (by post, phone or email)

AUTOMATED TECHNOLOGY

We  automatically collect personal data (technical and usage) when you  browse or interact with our website, by using cookies, server logs and  other similar technologies. We may also receive technical data about you  if you visit other websites which use our cookies.

PUBLICLY AVAILABLE SOURCES

WE  MAY COLLECT PERSONAL DATA FROM PUBLICLY AVAILABLY SOURCES SUCH AS  COMPANIES HOUSE AND THE ELECTORAL REGISTER AND CREDIT REFERENCE  AGENCIES, BASED INSIDE THE EU.

THIRD PARTIES

WE  MAY RECEIVE PERSONAL DATA FROM: (A) ANALYTICS PROVIDERS BASED OUTSIDE  THE EU (SUCH AS GOOGLE); (B) ADVERTISING NETWORKS BASED INSIDE OR  OUTSIDE THE EU]; AND (C) SEARCH INFORMATION PROVIDERS BASED INSIDE OR  OUTSIDE THE EU; (D) OUR SUPPLIERS SUCH AS PAYMENT PROVIDERS, DELIVERY  SERVICES, WEBSITE SUPPORT AND MAINTENANCE PROVIDERS.

  1. TC “4. How we use your personal data” 

4.1  We will only use your personal data when the law allows us to. Most commonly, we will use your personal data:

4.2  To perform the contract, we are to enter into or have entered into with you;

4.3  To comply with a legal obligation; and

4.4   Where it is necessary to carry out our legitimate interests (or those  of a third party) and your interests and fundamental rights do not  override those interests.

4.5  Part 2 of Schedule 1 sets out the lawful basis we will rely on to process your personal data.

4.6   We do generally only rely on consent as a legal basis for processing  your personal data to send email and SMS marketing communications and  you have the right to withdraw your consent at any time by contacting  us. Please note that we may process your personal data for more than one  lawful ground depending on the specific purpose for which we are using  your information.

4.7  We may analyse your personal data to form a view on what products and  or services we think may be of interest to you. You will only receive  marketing communications from us, if you have requested information from  us or purchased services from us, if you consent to marketing at the  time we collect your personal data and you have not subsequently opted  out or withdrawn your consent or if we have another basis to send you  the marketing communications. 

4.8  We will not share your personal data with third parties for their marketing purposes.

4.9   You can opt out of email marketing by clicking the unsubscribe button  within the marketing email. You can also withdraw your consent to  marketing at any time by contacting our DPM.

4.10  Even if you opt out of receiving marketing, we may still use your personal data for other purposes pro

vided we have a lawful basis to do so.

4.11   We will only use your personal data for the purpose that we originally  collected it for, unless we reasonably consider that we need to use it  for another reason and that reason is compatible with the original  purpose.

4.12   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 use  your personal data in this manner.

4.13  We may process your personal data (without your knowledge or consent) where this is required or permitted by law.

  1. TC “5. Disclosures of your personal data” 

5.1  We may have to share your personal data with third parties further  details of which are set out in Part 4 of Schedule 1. We require all  third parties to respect the security of your personal data and to treat  it in accordance with the law. We do not allow our third-party service  providers to use your personal data for their own purposes. They can  only process your personal data for specified purposes and in accordance  with our instructions. 

  1. TC “6. International transfers” 

6.1  We do not transfer your personal data outside the European Economic Area (EEA)

6.2  We normally do not share your personal data outside the European Economic Area (EEA).

6.3   Whenever we transfer your personal data out of the EEA, we ensure a  similar degree of protection is afforded to it by ensuring at least one  of the following safeguards is implemented:

6.4   We will only transfer your personal data to countries that have been  deemed to provide an adequate level of protection for personal data by  the European Commission.

6.5   We use specific contracts approved by the European Commission which  give personal data the same protection it has in Europe with our  services providers;  

6.6   We may transfer data to US based service providers under the Privacy  Shield which requires them to provide similar protection to personal  data shared between the Europe and the US.

6.7   Please contact us if you want further information on the specific  mechanism used by us when transferring your personal data.

  1. TC “7. Data security”

7.1   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. We also limit access to your  personal data to those employees, agents, contractors and other third  parties who have a business need to know and they can only process your  personal data on our instructions and will be subject to a duty of  confidentiality.

7.2   We have procedures in place 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.

  1. Data retention

8.1   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.

8.2   Details of retention periods for different aspects of your personal  data are available in our retention policy which you can request from  us.  However, we are legally required to keep basic information about  our customers (including contact, identity, financial and transaction  data) for six years after they cease being customers, for tax purposes.

8.3   We may also anonymise your personal data (so that it can no longer be  associated with you) for research or statistical purposes. We can use  anonymised information indefinitely without further notice to you.

  1. TC “9. Your legal rights” 

9.1   You have certain rights in certain circumstances under data protection  law.  These are set out in full in Part 3 of Schedule 1. If you wish to  exercise any of your rights, please contact our DPM.

9.2   You will not have to pay a fee to exercise any of your rights.  However, if your request is clearly unfounded, repetitive or excessive,  we may charge a reasonable fee for this information or refuse to comply  with your request.

9.3   We may request specific information from you to help us confirm your  identity when you contact us and ensure. This is a security measure to  ensure that personal data is not disclosed to any person who does not  have the right to receive it.

9.4   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.

Schedule 1: Personal Data

Part 1: Types of personal data

CONTACT DATA

BILLING ADDRESS, DELIVERY ADDRESS, EMAIL ADDRESS AND TELEPHONE NUMBER

FINANCIAL DATA

BANK ACCOUNT AND PAYMENT CARD DETAILS

IDENTITY DATA

FIRST NAME, MAIDEN NAME, LAST NAME, USERNAME OR SIMILAR IDENTIFIER, [MARITAL STATUS, TITLE, DATE OF BIRTH AND GENDER]

MARKETING AND COMMUNICATION DATA

YOUR PREFERENCES IN RECEIVING MARKETING FROM US [AND OUR THIRD PARTIES AND YOUR COMMUNICATION PREFERENCES]

PROFILE DATA

YOUR USERNAME AND PASSWORD, [PURCHASE OR ORDERS MADE BY YOU,] PREFERENCES, FEEDBACK [AND SURVEY RESPONSES]

TECHNICAL DATA

internet  protocol (IP) address, your login data, browser type and version, time  zone setting and location, browser plug-in types and versions, operating  system and platform and other technology on the devices you use to  access our website

TRANSACTION DATA

[DETAILS ABOUT PAYMENTS TO AND FROM YOU AND OTHER DETAILS OF PRODUCTS AND SERVICES YOU HAVE PURCHASED FROM US]

Part 2: Lawful basis for processing and processing activities

The lawful basis upon which we may rely on to process your personal data are:

CONSENT

YOU HAVE GIVEN YOUR EXPRESS CONSENT FOR US TO PROCESS YOUR PERSONAL DATA FOR A SPECIFIC PURPOSE

CONTRACT

THE  PROCESSING IS NECESSARY FOR US TO PERFORM OUR CONTRACTUAL OBLIGATIONS  WITH YOU UNDER OUR CONTRACT, OR BECAUSE YOU HAVE ASKED US TO TAKE  SPECIFIC STEPS BEFORE ENTERING INTO A CONTRACT WITH YOU

LEGAL OBLIGATION

THE PROCESSING IS NECESSARY FOR US TO COMPLY WITH LEGAL OR REGULATORY OBLIGATION.

LEGITIMATE INTERESTS

THE  PROCESSING IS NECESSARY FOR OUR OR A THIRD PARTY’S LEGITIMATE INTEREST  E.G. IN ORDER FOR US TO PROVIDE THE BEST SERVICE TO YOU VIA OUR WEBSITE.  BEFORE WE PROCESS YOUR PERSONAL DATA ON THIS BASIS WE MAKE SURE WE  CONSIDER AND BALANCE ANY POTENTIAL IMPACT ON YOU, AND WE WILL NOT USE  YOUR PERSONAL DATA ON THIS BASIS WHERE SUCH IMPACT OUTWEIGHS OUR  INTEREST

Set  out below are specific details of the processing activities we  undertake with your personal data and the lawful basis for doing this.

Purpose/Activity

Type of data

Lawful basis for processing

to register you as a new customer

identity & contact

to perform our contract with you

to process and deliver your order, manage payments, fees and charges and debt recovery

identity, contact, financial, transaction and marketing & communications

(i) to perform our contract with you;

(ii) as necessary for our legitimate interest in recovering debts due to us.

to  manage our relationship with you, notifying you about changes to our  Terms or Privacy Policy and ask you to leave a review [or take a survey]

identity, contact, profile & marketing & communications

(i) to perform our contract with you

(ii) as necessary to comply with a legal obligation

(iii)  as necessary for our legitimate interests in keeping our records  updated and analysing how customers use our products/services.

to  administer and protect our business and this website (including  troubleshooting, data analysis, testing, system maintenance, support,  reporting and hosting of data)

identity, contact & technical

(i)  as necessary for our legitimate interests in 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

(ii) as necessary to comply with any legal obligations

to deliver relevant website content/advertisements to you and measure or understand the effectiveness of our advertising

identity, contact, profile, usage, marketing & communications & technical

as  necessary for our legitimate interests in studying how customers use  our products/services, to develop them, to grow our business and to  inform our marketing strategy

to use data analytics to improve our website, products/services, marketing, customer relationships and experiences

technical & usage

as  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, including promotional offers

identity, contact, technical, usage & profile

as necessary for our legitimate interests to develop our products/services and grow our business

Part 3: Your legal rights

You have the following legal rights in relation to your personal data:

ACCESS YOUR DATA

YOU CAN ASK FOR ACCESS TO AND A COPY OF YOUR PERSONAL DATA AND CAN CHECK WE ARE LAWFULLY PROCESSING IT

CORRECTION

YOU CAN ASK US TO CORRECT ANY INCOMPLETE OR INACCURATE PERSONAL DATA WE HOLD ABOUT YOU

ERASURE

YOU CAN ASK US TO DELETE OR REMOVE YOUR PERSONAL DATA WHERE:

(A) THERE IS NO GOOD REASON FOR US CONTINUING TO PROCESS IT;

(B) YOU HAVE SUCCESSFULLY EXERCISED YOUR RIGHT TO OBJECT (SEE BELOW);

(C) WE MAY HAVE PROCESSED YOUR INFORMATION UNLAWFULLY; OR

(D) WE ARE REQUIRED TO ERASE YOUR PERSONAL DATA TO COMPLY WITH LOCAL LAW.

(E)  WE MAY NOT ALWAYS BE ABLE TO COMPLY WITH YOUR REQUEST FOR SPECIFIC  LEGAL REASONS, WHICH WILL BE NOTIFIED TO YOU AT THE TIME OF YOUR REQUEST

OBJECT

YOU CAN OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA WHERE:

(A)  WHERE WE ARE RELYING ON OUR LEGITIMATE INTEREST (OR THOSE OF A THIRD  PARTY) AS THE BASIS FOR PROCESSING YOUR PERSONAL DATA, IF YOU FEEL IT  IMPACTS ON YOUR FUNDAMENTAL RIGHTS AND FREEDOMS;

(B) WHERE WE ARE PROCESSING YOUR PERSONAL DATA FOR DIRECT MARKETING PURPOSES.

(C)  IN SOME CASES, WE MAY DEMONSTRATE THAT WE HAVE COMPELLING LEGITIMATE  GROUNDS TO PROCESS YOUR INFORMATION WHICH OVERRIDE YOUR RIGHTS AND  FREEDOMS, AND, IN SUCH CIRCUMSTANCES, WE CAN CONTINUE TO PROCESS YOUR  PERSONA DATA FOR SUCH PURPOSES

RESTRICT PROCESSING

YOU CAN ASK US TO US TO SUSPEND OR RESTRICT THE PROCESSING OF YOUR PERSONAL DATA, IF:

(A) YOU WANT US TO ESTABLISH THE ACCURACY OF YOUR PERSONAL DATA;

(B) OUR USE OF YOUR PERSONAL DATA IS UNLAWFUL, BUT YOU DO NOT WANT US TO ERASE IT;

(C)  YOU NEED US TO HOLD YOUR PERSONAL DATA (WHERE WE NO LONGER REQUIRE IT)  AS YOU NEED IT TO ESTABLISH, EXERCISE OR DEFEND LEGAL CLAIMS; OR

(D)  YOU HAVE OBJECTED TO OUR USE OF YOUR PERSONAL DATA, BUT WE NEED TO  VERIFY WHETHER WE HAVE OVERRIDING LEGITIMATE GROUNDS TO USE IT

REQUEST A TRANSFER

YOU  CAN REQUEST A TRANSFER OF YOUR PERSONAL DATA WHICH IS HELD IN AN  AUTOMATED MANNER AND WHICH YOU PROVIDED YOUR CONSENT FOR US TO PROCESS  SUCH PERSONAL DATA OR WHICH WE NEED TO PROCESS TO PERFORM OUR CONTACT  WITH YOU, TO YOU OR A THIRD PARTY. WE WILL PROVIDE YOUR PERSONAL DATA IN  A STRUCTURED, COMMONLY USED, MACHINE-READABLE FORMAT

WITHDRAW YOUR CONSENT

YOU CAN WITHDRAW YOUR CONSENT AT ANY TIME (WHERE  WE ARE RELYING ON CONSENT TO PROCESS YOUR PERSONAL DATA). THIS DOES NOT  AFFECT THE LAWFULNESS OF ANY PROCESSING CARRIED OUT BEFORE YOU WITHDRAW  YOUR CONSENT

Part 4: Third Parties

SERVICE PROVIDERS

ACTING  AS PROCESSORS OR CONTROLLERS BASED IN THE EEA BUT ALSO AROUND THE WORLD  WHO PROVIDE [DETAILS] SERVICES AND IT AND SYSTEM ADMINISTRATION  SERVICES.

PROFESSIONAL ADVISORS

[ACTING  AS PROCESSORS OR JOINT CONTROLLERS] INCLUDING LAWYERS, BANKERS,  AUDITORS AND INSURERS BASED IN THE UNITED KINGDOM WHO PROVIDE  CONSULTANCY, BANKING, LEGAL, INSURANCE AND ACCOUNTING SERVICES

HM REVENUE & CUSTOMS, REGULATORS AND OTHER AUTHORITIES

[ACTING  AS PROCESSORS OR JOINT CONTROLLERS] BASED IN THE EEA WHO REQUIRE  REPORTING OF PROCESSING ACTIVITIES IN CERTAIN CIRCUMSTANCES

THIRD PARTIES

THIRD  PARTIES WHOM WE MAY CHOOSE TO SELL, TRANSFER, OR MERGE PARTS OF OUR  BUSINESS OR OUR ASSETS. ALTERNATIVELY, WE MAY SEEK TO ACQUIRE OTHER  BUSINESSES OR MERGE WITH THEM. IF A CHANGE HAPPENS TO OUR BUSINESS, THEN  THE NEW OWNERS MAY USE YOUR PERSONAL DATA IN THE SAME WAY AS SET OUT IN  THIS PRIVACY POLICY

         Part 5: Glossary

AGGREGATED DATA

INFORMATION  SUCH AS STATISTICAL OR DEMOGRAPHIC DATA WHICH MAY BE DERIVED FROM  PERSONAL DATA, BUT WHICH CANNOT BY ITSELF IDENTIFY A DATA SUBJECT

CONTROLLER

A BODY THAT DETERMINES THE PURPOSES AND MEANS OF PROCESSING PERSONAL DATA

DATA SUBJECT

AN INDIVIDUAL LIVING PERSON IDENTIFIED BY PERSONAL DATA (WHICH WILL GENERALLY BE YOU)

PERSONAL DATA

INFORMATION  IDENTIFYING A DATA SUBJECT FROM THAT DATA ALONE OR WITH OTHER DATA WE  MAY HOLD BUT IT DOES NOT INCLUDE ANONYMISED OR AGGREGATED DATA

PROCESSOR

A BODY THAT IS RESPONSIBLE FOR PROCESSING PERSONAL DATA ON BEHALF OF A CONTROLLER

SPECIAL CATEGORIES OF PERSONAL DATA

INFORMATION  ABOUT RACE, ETHNICITY POLITICAL OPINIONS, RELIGIOUS OR PHILOSOPHICAL  BELIEFS, TRADE UNION MEMBERSHIP, HEALTH, GENETIC, BIOMETRIC DATA, SEX  LIFE, SEXUAL ORIENTATION.

ICO

INFORMATION COMMISSIONER’S OFFICE, THE UK’S SUPERVISORY AUTHORITY FOR DATA PROTECTION ISSUES

  1. Changes to this Policy

10.1 Knead This LTD reserves the right to change this Privacy Policy as  we may deem necessary from time to time or as may be required by law.   Any changes will be immediately posted on the Web Site and you are  deemed to have accepted the terms of the Policy on your first use of the  Web Site following the alterations.