The policy is provided in convenient sections so you can find the information you need.
- Important information and who we are
- The data we collect about you
- How your personal data is collected
- How we use your personal data
- Disclosures of your personal data
- International transfers
- Data security
- Data retention
- Your legal rights
1. Important information and who we are
This website is not intended for children and we do not knowingly collect data relating to children.
Email address: email@example.com
Postal address: 84 Pembroke Road, London, W8 6NX
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (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.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you as follows:
- Identity Data includes first name, last name, username or similar identifier, title, date of birth and social media accounts.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes payment card details, PayPal details and gift card or referral credit.
- Transaction Data includes details about payments to and from you and other details of products, any subscriptions you have ordered and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, advertising channels used to arrive at our website, referral pages, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data includes your username and password, referrals you have made, purchases or orders made by you, your food preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
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.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, if you do not provide us with a correct address we cannot send orders to you). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you, including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us or contacting us by post, phone, email or otherwise. This includes personal data you provide when you:
- order our products or services;
- create an account on our website;
- subscribe to make regular orders;
- refer a friend;
- request for marketing to be sent to you; or
- enter a competition, promotion or survey.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
- analytics providers such as Google Analytics (based both outside and inside of the EU and the UK); and
- advertising networks such as Google Ads (based both inside and outside of the EU and the UK).
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services, such as the Royal Mail (based inside the UK) or Stripe (based both inside and outside and of the EU and the UK).
- Identity and Contact Data from publicly available sources such as Twitter, Facebook, Instagram, TikTok and similar social media platforms.
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:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us or by using the “unsubscribe” option provided in our marketing emails.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
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 data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer or to open your account||(a) Identity (b) Contact (c) Profile (d) Marketing and Communications||(a) Performance of a contract with you (b) Consent|
|To sign you up to a marketing mailing list||(a) Identity (b) Contact (d) Marketing and Communications||(a) Performance of a contract with you (b) Consent|
|To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us||(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (f) Profile||(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (keeping a record of transactions for tax and accounting purposes)|
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications||(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 and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity (b) Contact (c) Technical||(a) Necessary for our legitimate interests (for running our business, improving our website, 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 (ensuring the security and integrity of our systems and the personal data that we hold)|
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we send to you||(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical||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 use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical (b) Usage||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||(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications||Necessary for our legitimate interests (to develop our products/services and grow our business)|
|To interact with you on social media||(a) Identity (b) Contact||Necessary for our legitimate interests (to engage with our customers, to study how customers use our products/services, to grow our business and to inform our marketing strategy)|
We do our best 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 (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
We will always get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by either (i) logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences; (ii) by following the opt-out links on any marketing message sent to you; or (iii) by contacting us at any time.
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 us.
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.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table ‘Purposes for which we will use your personal data’ above.
- External Third Parties as set out in the Glossary.
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 and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
We do not transfer your personal data outside the European Economic Area (EEA) or the UK.
Many of our external third parties are based outside the EEA and/or the UK so their processing of your personal data may involve a transfer of data outside the EEA and/or the UK. Whenever they do so, we always ensure that a similar degree of protection is afforded to your data by ensuring at least one of the following safeguards is implemented by that third party:
- Transfers of personal data may be made to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission and/or any other relevant authority. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Specific contracts approved by the European Commission and/or any other relevant authority which give personal data the same protection it has in Europe/the UK are in place. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- That third party has binding corporate rules in place in compliance with the relevant data protection laws.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA and/or the UK.
7. 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. We use strong user authenticated access to our systems and we are constantly improving and upgrading our systems’ security. 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.
8. Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have 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.
In some circumstances you can ask us to delete your data: see [your legal rights] below for further information.
In some circumstances we will 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.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have the right to:
Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
These rights are set out on the ICO website and can be found here: https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
If you wish to exercise any of the rights set out above, please contact our data privacy manager.
No fee usually required
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 fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could 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 as soon as we can, typically within 5 working days, but it could take up to one month. Occasionally it could 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.
What are cookies?
Cookies are a technology that can be used to provide you with tailored information from a web site by distinguishing you from other users. A cookie is an element of data that a web site can send to your browser, which may then be stored on your computer system. This element of data is a piece of text file of letters and number, not a program that we store on your browser or hard drive of your computer if you agree. The Site can only access the information from a cookie sent by the Site. We cannot access other cookies sent by other web sites or the information contained therein. Additionally, we cannot learn your email address or any other information about you through the use of a cookie. The only way we would learn such information is if you specifically submit that information to us.
- To estimate our audience size and usage pattern.
- To store information about your preferences, and so allow us to customise our websites according to your individual interests.
- To speed up your searches.
- To recognise you when you return to our websites.
May I decline to accept a cookie?
You may decline to accept cookies sent by the Site by selecting an option on your browser to reject cookies or you can also use the Cookie panel to make your choice. However, if you use your browser settings to block all cookies you may not be able to access all parts of our site.
What benefits do I receive from cookies?
We use the following cookies:
Strictly Necessary Cookies
These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.
These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant advertisements on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site and will not be able to monitor its performance.
These cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies, then some or all of these services may not function properly.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract 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.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
External Third Parties
- Service providers acting as processors, including:
- Woocommerce, who provide order processing and system administration services based in the UK, EU, USA and Canada;
- Royal Mail, a logistics provider based in the UK;
- Yodel, a logistics provider based in the UK;
- DHL, a logistics provider based in the UK;
- Hermes, a logistics provider based in the UK;
- Various software and website development agencies based in the UK, EU & Canada;
- Google, who provide analytics and advertising services hosted both outside and inside of the EU and the UK;
- Meta, who provide analytics and advertising services hosted both outside and inside of the EU and the UK;
- Twitter, who provide analytics and advertising services hosted both outside and inside of the EU and the UK; and
- Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the UK 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 United Kingdom who require reporting of processing activities in certain circumstances.