Privacy Policy
1.
INTRODUCTION
This privacy notice provides you with details of
how we collect and process your personal data through your use of our site
www.vclean.life, including any information you may provide through our site
when you purchase a product or service, sign up to our newsletter or take part
in a prize draw or competition.
By providing us with your data, you warrant to us
that you are over 13 years of age.
Niki Byrne of Breakfast delivery UK is the data
controller and is responsible for your personal data (referred to as “we”, “us”
or “our” in this privacy notice).
We have appointed a Data Protection Officer who is
in charge of privacy related matters for us. If you have any questions about
this privacy notice, please contact the Data Protection Officer using the
details set out below.
Niki Byrne
Breakfast Delivery UK Ltd
304 Pill Box
115 Coventry Road
London
E2 6GG
Our full details are:
Full name of legal entity: Breakfast Delivery UK
Ltd
Name or title of Data Protection Officer: Niki
Byrne
Email address: Niki@thebreakfast.co
If you are not happy with any aspect of how we
collect and use your data, you have the right to complain to the Information
Commissioner’s Office (ICO), the UK supervisory authority for data protection
issues (www.ico.org.uk). We should be grateful if you would
contact us first if you do have a complaint so that we can try to resolve it
for you.
It is very important that the information we hold
about you is accurate and up to date. Please let us know if at any time your
personal information changes by emailing us at enquiries@thebreakfast.co
2. WHAT DATA DO WE COLLECT
ABOUT YOU
Personal data means any information capable of
identifying an individual. It does not include anonymised data.
We may process certain types of personal data about
you as follows:
1. Identity Data may
include your first name, maiden name, last name, username, marital status,
title, date of birth and gender.
2. Contact Data may
include your billing address, delivery address, email address and telephone
numbers.
3. Financial Data may
include your bank account and payment card details.
4. Transaction Data may
include details about payments between us and other details of purchases made
by you.
5. Technical Data may
include your login data, internet protocol addresses, browser type and version,
browser plug-in types and versions, time zone setting and location, operating
system and platform and other technology on the devices you use to access this
site.
6. Profile Data may
include your username and password, purchases or orders, your interests,
preferences, feedback and survey responses.
7. Usage Data may
include information about how you use our website, products and services.
8. Marketing and
Communications Data may include your preferences in receiving
marketing communications from us and our third parties and your communication
preferences.
We may also process Aggregated Data from your
personal data but this data does not reveal your identity and as such in itself
is not personal data. An example of this is where we review your Usage Data to
work out the percentage of website users using a specific feature of our site.
If we link the Aggregated Data with your personal data so that you can be
identified from it, then it is treated as personal data.
Where we are required to collect personal data by
law, or under the terms of the contract between us and you do not provide us
with that data when requested, we may not be able to perform the contract (for
example, to deliver goods or services to you). If you don’t provide us with the
requested data, we may have to cancel a product or service you have ordered but
if we do, we will notify you at the time.
2.
HOW WE COLLECT YOUR
PERSONAL DATA
We collect data about you through a variety of
different methods including:
1. Direct interactions: You
may provide data by filling in forms on our site (or otherwise) or by
communicating with us by post, phone, email or otherwise, including when you:
1. order our products or
services;
2. create an account on our
site;
3. subscribe to our service or
publications;
4. request resources or
marketing be sent to you;
5. enter a competition, prize
draw, promotion or survey; or
6. give us feedback.
2. Automated technologies or
interactions: As you use our site, we may automatically collect
Technical Data about your equipment, browsing actions and usage patterns. We
collect this data by using cookies, server logs and similar technologies. We
may also receive Technical Data about you if you visit other websites that use
our cookies. Please see our cookie policy at for
further details.
|
Purpose/Activity
|
Type
of data
|
Lawful
basis for processing
|
|
To register you as a new customer
|
(a) Identity
(b) Contact
|
Performance of a contract with you
|
|
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
|
(a) Performance of a contract with you
(b) Necessary for our legitimate interests to recover debts owed to us
|
|
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
|
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
|
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests to keep our records updated and to
study how customers use our products/services
|
|
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 our site (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,
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
|
|
To deliver relevant content and advertisements to you and measure and
understand the effectiveness of our advertising
|
(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 site 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
|
Necessary for our legitimate interests to develop our
products/services and grow our business
|
3. Third parties or publicly
available sources: We may receive personal data about you from various
third parties and public sources as set out below:
1. analytics providers such as
Google based outside the EU;
2. advertising networks based
inside OR outside the EU; and
3. search information providers
inside OR outside the EU
4. Contact, Financial and
Transaction Data from providers of technical, payment and delivery services
based inside OR outside the EU
5. Identity and Contact Data
from data brokers or aggregators based inside OR outside the
EU
6. Identity and Contact Data
from publicly availably sources such as Companies House and the Electoral
Register based inside the EU
4. HOW WE USE YOUR
PERSONAL DATA
We will only use your personal data when legally
permitted. The most common uses of your personal data are:
1. Where we need to perform the
contract between us.
2. 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.
3. Where we need to comply with
a legal or regulatory obligation.
Generally, we do not rely on consent as a legal
ground for processing your personal data, other than in relation to sending
marketing communications to you via email or text message. You have the right
to withdraw consent to marketing at any time by emailing us at enquiries@thebreakfast.co
PURPOSES FOR PROCESSING
YOUR PERSONAL DATA
Set out below is a description of the ways we
intend to use your personal data and the legal grounds on which we will process
such data. We have also explained what our legitimate interests are where
relevant.
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 email us at enquiries@thebreakfast.co 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.
MARKETING COMMUNICATIONS
You will receive marketing communications from us
if you have:
1. Requested information from
us or purchased goods or services from us; or
2. If you provided us with your
details and ticked the box at the point of entry of your details for us to send
you marketing communications; and
3. In each case, you have not
opted out of receiving that marketing.
We will 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 logging into the website and checking or
unchecking relevant boxes to adjust your marketing preferences] OR [by
following the opt-out links on any marketing message sent to you or] OR by
emailing us at enquiries@thebreakfast.co at any time.
Where you opt out of receiving our marketing
communications, this will not apply to personal data provided to us as a result
of a product/service purchase, warranty registration, product/service
experience or other transactions.
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 find out more about how the processing for the new
purpose is compatible with the original purpose, please email us at enquiries@thebreakfast.co
If we need to use your personal data for a purpose
unrelated to the purpose for which we collected the data, we will notify you
and we will explain the legal ground of processing.
We may process your personal data without your knowledge
or consent where this is required or permitted by law.
5. DISCLOSURES OF YOUR
PERSONAL DATA
We may have to share your personal data with the
parties set out below for the purposes set out in the table in paragraph 4
above:
1. Service providers who
provide IT and system administration services.
2. Professional advisers
including lawyers, bankers, auditors and insurers who provide consultancy,
banking, legal, insurance and accounting services.
3. HM Revenue & Customs,
regulators and other authorities based in the United Kingdom and other relevant
jurisdictions who require reporting of processing activities in certain
circumstances.
4. Third parties to whom we
sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer
your data to respect the security of your personal data and to treat it in
accordance with the law. We only allow such third parties to process your
personal data for specified purposes and in accordance with our instructions.
We do not transfer your personal data outside the
European Economic Area (EEA).
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. 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 such data. 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 necessary to fulfil the purposes we collected it for, including for the
purposes of satisfying any legal, accounting, or reporting requirements.
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
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 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.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under
data protection laws in relation to your personal data. These include the right
to:
1. Request access to your
personal data.
2. Request correction of your
personal data.
3. Request erasure of your
personal data.
4. Object to processing of your
personal data.
5. Request restriction of
processing your personal data.
6. Request transfer of your
personal data.
7. Right to withdraw consent.
You can see more about these rights at:
https://ico.org.uk/for-organis...
If you wish to exercise any of the rights set out
above, please email us at enquiries@thebreakfast.co
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 may refuse to comply with your request in these
circumstances.
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.
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.
10. THIRD-PARTY LINKS
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. When you leave our website, we encourage you to read the
privacy notice of every website you visit.
11. 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.
...
What's a cookie?
- A
"cookie" is a piece of information that is stored on your
computer's hard drive and which records how you move your way around a
website so that, when you revisit that website, it can present tailored
options based on the information stored about your last visit. Cookies can
also be used to analyse traffic and for advertising and marketing
purposes.
- Cookies are
used by nearly all websites and do not harm your system.
·
If you want to check or change what types of cookies you accept, this
can usually be altered within your browser settings. You can block cookies at
any time by activating the setting on your browser that allows you to refuse
the setting of all or some cookies. However, if you use your browser settings
to block all cookies (including essential cookies) you may not be able to
access all or parts of our site.
·
How do we use cookies?
- We use cookies
to track your use of our website. This enables us to understand how you
use the site and track any patterns with regards how you are using our
website. This helps us to develop and improve our website as well as
products and / or services in response to what you might need or want.
- Cookies are
either:
- Session
cookies: these are only stored on your computer during your web session
and are automatically deleted when you close your browser – they usually
store an anonymous session ID allowing you to browse a website without
having to log in to each page but they do not collect any personal data
from your computer; or
- Persistent cookies:
a persistent cookie is stored as a file on your computer and it remains
there when you close your web browser. The cookie can be read by the
website that created it when you visit that website again. [We use
persistent cookies for Google Analytics.]
- Cookies can
also be categorised as follows:
- Strictly
necessary cookies: These cookies are essential to enable you to use the
website effectively, such as when buying a product and / or service, and
therefore cannot be turned off. Without these cookies, the services
available to you on our website cannot be provided. These cookies do not
gather information about you that could be used for marketing or
remembering where you have been on the internet.
- Performance
cookies: These cookies enable us to monitor and improve the performance
of our website. For example, they allow us to count visits, identify
traffic sources and see which parts of the site are most popular.
- Functionality
cookies: These cookies allow our website to remember choices you make and
provide enhanced features. For instance, we may be able to provide you
with news or updates relevant to the services you use. They may also be
used to provide services you have requested such as viewing a video or
commenting on a blog. The information these cookies collect is usually
anonymised.