SECTION 1 – INTRODUCTION
1.1 We are committed to safeguarding the privacy of our website visitors; in this policy we explain how we will treat your personal information.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of Food At Heart visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
1.4 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications. You can notify us of your wish to limit any communications by contacting Meredith Whitely at firstname.lastname@example.org.
1.5 In this policy, “we”, “us” and “our” refers to Food At Heart.
SECTION 2 – CREDIT
2.1 This document was created using a template from SEQ Legal (http://www.seqlegal.com).
SECTION 3 – HOW WE USE YOUR PERSONAL DATA
3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
3.2 Website usage data
We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is consent as part of using our website/services and our legitimate interests, namely monitoring and improving our website and services.
3.3 Profile data
We may process your information included in your personal profile on our website (“profile data“). The profile data may include your name, address, telephone number, email address and dietary information. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR to fulfil legal obligations connected to health and safety of food supply.
3.4 Service fulfillment data
We may process your personal data that are provided in the course of the use of our services (“service data“). The service data may include name, address, telephone number, email address, health information, purchase details and payment history. The source of the service data is you, and this may on occasion come via a third party booking supplier if you have booked our events on an external events website rather than on foodatheart.co.uk. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract OR to fulfil legal and insurance requirements necessary to provide these services (in particular the delivery of meditation sessions).
3.5 Publication Data
We may process information that you post for publication on our website or through our services (“publication data“), such as comments on blog posts. The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business.
3.6 Enquiry Data
We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.
3.7 Customer Relationship Data
We may process information relating to our customer relationships, including customer contact information (“customer relationship data“). The customer relationship data may include your name, contact details, payment history and information contained in communications between us. The source of the customer relationship data is you. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is consent OR our legitimate interests, namely the proper management of our customer relationships.
3.8 Transaction Data
We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data“). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business. Card details are not held by Food At Heart and onsite payments are processed using Stripe Payments Europe, Ltd.
3.9 Notification/Marketing Data
We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. You will have provided your details when you purchased goods or services from us; or when you entered a competition or registered for a promotion or free resources; and in each case, you have not opted out of receiving that marketing. The legal basis for this processing is consent OR our legitimate interests, namely the proper management of our relationships.
3.10 Correspondence Data
We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
3.11 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.12 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.13 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3.14 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
SECTION 4 – USING PERSONAL INFORMATION SUMMARY
4.1 To summarise and confirm what is set out in Section 3, personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website.
4.2 We may use your personal information to:
(a) administer our website and business;
(b) personalise our website for you;
(c) enable your use of the services available on our website;
(d) send you goods purchased through our website;
(e) supply to you services purchased through our website;
(f) send statements, invoices and payment reminders to you, and collect payments from you;
(g) send you non-marketing commercial communications;
(h) send you email notifications that you have specifically requested;
(i) send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter);
(j) send you marketing communications relating to our business which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);
(k) provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information);
(l) provide third party event providers listed on Food At Heart with the necessary information for you to attend their events;
(m) deal with enquiries and complaints made by or about you relating to our website;
(n) keep our website secure and prevent fraud;
(o) verify compliance with the terms and conditions governing the use of our website.
4.3 If you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the licence you grant to us.
4.4 Your privacy settings can be used to limit the publication of your information on our website, and can be adjusted using privacy controls on the website.
4.5 We will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party’s direct marketing.
SECTION 5 – DISCLOSING PERSONAL INFORMATION
5.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5.2 We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.
5.3 We may disclose your personal information:
(a) to event partners from whom you have purchased any joint activities and/or events to allow them to confirm your attendance and ability to participate in purchased events;
(b) to the extent that we are required to do so by law;
(c) in connection with any ongoing or prospective legal proceedings;
(d) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
(e) to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and
(f) to any person whom we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
5.4 We may disclose aggregated site usage data and event data to Cosmik Carrot for the purposes of website and server management to allow for the delivery of our website and services.
5.5 Financial transactions relating to our website and services are handled by our payment services providers, Stripe Payments. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at https://stripe.com/gb/privacy.
5.6 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5.7 Except as provided in this policy, we will not provide your personal information to third parties.
SECTION 6 – DATA PROCESSING & INTERNATIONAL DATA TRANSFERS
6.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA). Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy.
6.2 The hosting facilities for our website are situated in Bulgaria. This is located within the European Economic Area (EEA).
6.3 We currently use the following third party providers for processing and/or handling of data:
(a) Google Analytics – to collect information on website usage to track and improve website usability; Google is based in the United States of America and transfers will be protected by appropriate safeguards, covered by the Google Privacy Shield
(b) Stripe Payments – to securely process payment transactions and track payment history; Stripe Payments are processed in Europe via Stripe Payments Europe Limited in Ireland and further transfers are covered by Stripe’s Privacy Shield Policy
(c) Xero – to track payments information to and from suppliers (including storing contact and payment details for these suppliers); Xero processes and stores data via Amazon Web Services in the United States of America and some data is processed in New Zealand; this is covered by Xero’s Model Clauses and further information can be found at https://www.xero.com/uk/about/privacy/
(d) Cosmik Carrot – to provide website hosting and maintenance and usability of website; further information on these services can be found at https://www.cosmikcarrot.com/privacy-policy/
(e) Mailchimp – to collect and manage name and email information used for the purposes of communicating with current and potential customers, and to deliver contractual obligations (e.g. purchase of products that includes email communications); Mailchimp processes data in the United States of America and is covered by the Mailchimp Privacy Shield Policy
(f) Facebook – to create custom and lookalike audiences for the purposes of marketing and targeting; Facebook data is processed in the United States of America and is covered by the Facebook Privacy Shield Policy
The European Commission has made an “adequacy decision” with respect to the data protection laws of each of the above countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from the locations noted above.
6.4 We also collect personal data:
(a) for the purposes of delivering products and collecting email information that may be used with consent for future marketing via WordPress using Event Espresso (WordPress Plugin) and Sumo (WordPress Plugin).
(b) from third party event and marketplace websites to fulfil contractual obligations for products/services purchased and in order to communicate with customers in relation to this; the current list of websites that supply this information include Eventbrite, Billetto, Funzing, Obby, etsy, TheFoodMarket.com
6.5 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
6.5 Information that we collect may be transferred to the following countries which do not have data protection laws equivalent to those in force in the European Economic Area: the United States of America, Russia, Japan, China and India.
6.6 You expressly agree to the transfers of personal information described in this Section 6.
SECTION 7 – RETAINING AND DELETING PERSONAL INFORMATION
7.1 This Section 7 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
7.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
7.3 We will retain your personal data as follows:
(a) personal data, cookie information and purchase history will be retained for a minimum period of 2 years following the provision of information and for a maximum period of 5 years following the provision of information.
7.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on requirements for fulfilling our services or contractual obligations.
7.5 Notwithstanding the other provisions of this Section 7, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
SECTION 8 – SECURITY OF PERSONAL INFORMATION
8.1 We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information as set out in the General Data Protection Regulation.
8.2 You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
SECTION 9 – AMENDMENTS
9.1 We may update this policy from time to time by publishing a new version on our website.
9.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
9.3 We will notify you of significant changes to this policy by email.
SECTION 10 – YOUR RIGHTS
10.1 In this Section 10, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
10.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
10.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
10.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
10.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
10.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
10.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
10.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
10.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
10.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
10.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
10.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
10.13 You may exercise any of your rights in relation to your personal data by written notice to us either by email to Meredith Whitely (email@example.com) or by post to Food At Heart, 88 Heath Road, Beaconsfield, Bucks HP9 1DJ.
SECTION 11 – THIRD PARTY WEBSITES
11.1 Our website includes hyperlinks to, and details of, third party websites.
11.2 We have no control over, and are not responsible for, the privacy policies and practices of these third parties.
SECTION 12 – COOKIES
12.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
12.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
SECTION 13 – COOKIES THAT WE USE
13.1 We use “analytical” cookies for the following purposes:
– Estimate our audience size and usage patterns
– Store information about your preferences, and so allow us to customise our site and to provide you with offers that are targeted at your individual interests
– Recognise you when you return to our site
SECTION 14 – COOKIES USED BY OUR SERVICE PROVIDERS
SECTION 15 – MANAGING COOKIES
15.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
15.2 Blocking all cookies will have a negative impact upon the usability of many websites.
15.3 If you block cookies, you will not be able to use all the features on our website.
SECTION 16 – OUR DETAILS
16.1 This website is owned and operated by Food At Heart and our registered office is at 88 Heath Road, Beaconsfield, Buckinghamshire HP9 1DJ, UK.
16.2 You can contact us with any comments or questions by writing to the business address given above, by:
(a) using our website contact form
(b) by email to firstname.lastname@example.org
(c) by post at the above postal address.
16.3 All data protection questions should be directed to the details above.