Last revised: August, 2018
ABOKADO is a trading name of ELVETHAM LIMITED (we/us/our). We are committed to respecting your privacy and protecting your personal data. We recognise that your personal data is your property and that you have loaned it to us for specific purposes, which we need in order to run our business operations and provide our products to you.
Unless otherwise required by law, the Information Commissioner’s Office (ICO) guidance or best practice, or in order to perform our contract with you, we will only process your personal data in the way we tell you or in the way you ask us to, and we will give it back to you at any time.
1.1 This policy sets out how we will process your personal data. Together with our standard terms and conditions of sale (available on our website at www.abokado.com (our Website) and any other documents we provide to you as part of your trading relationship with us, this policy will form part of our contract with you. You are therefore advised to read it carefully.
1.2 Terms used within it shall have the meaning(s) given in the Data Protection Act 2018 (Act) and/or the General Data Protection Regulation (Regulation), as applicable.
1.3 By providing your personal data to us, whether through buying our products or visiting our Website, you understand and accept the practices described in this policy.
1.4 Any changes we make to this policy will be posted on this page. You are advised to check back frequently as, unless your consent is required, any changes will be binding on you when you continue to provide your personal data after the date of the relevant change.
1.5 For more information relating to your rights under this policy, please see section 9.
1.6 If you have any queries relating to this policy, please contact us at email@example.com in the first instance.
2.1 For the purposes of the Act, the data controller is Elvetham Limited, a company registered in England & Wales (number 04817215) with our registered office at 6 Snow Hill, London EC1A 2AY.
2.2 We are registered with the ICO to process your personal data and our registration number is Z9610387.
3.1 We do not ordinarily rely on your consent to process your personal data. We process your personal data primarily to perform our contract with, and sell our products to, you. We consider the personal data we obtain is reasonable and necessary for these purposes. However, we review this intermittently and remove any inaccurate or obsolete data.
3.2 By using our Website and/or buying our products, you expressly consent to the transfers of your personal data to those specifically listed third parties in this policy, for the reasons specified.
3.3 We will attempt to market our products to you in or around our stores, through email marketing campaigns run by third parties on our behalf (see section 4.9 onwards) and through mainstream social media channels.
3.4 You may exercise your rights under section 9 at any time, which includes withdrawing your consent to our processing of your personal data. However, where this withdrawal prevents us from performing our contract with you, we may not be able to provide our goods and services to you.
4.1 Where you are one of our suppliers, we will only collect your business contact details for the purposes of contacting you in relation to your supply of products to us. This may include your name, address, telephone number and email address (typically of our appointed account manager). We collect this during the contractual negotiation phase.
4.2 Where you are a business customer purchasing off site, we will collect your business contact details for the purposes of your order and we may pass these details to our appointed couriers so that they can deliver your order.
4.3 Where you are an ordinary customer who purchases our products in store, any bank or credit or debit card details you provide in order to make payment for your order, will be retained only by WorldPay (our appointed payment card processor). Footage of you may also be recorded on CCTV (see section 5.3).
4.4 Where you are a current, potential or former employee, worker or other member of our staff, we may collect additional categories of your personal data for the purposes of providing you with the necessary benefits under our contract with you. In those circumstances, a separate privacy notice applies and a copy is available to staff on request.
4.5 Where you wish to raise any enquiry, complaint or provide feedback, we ask you to do this through our Website. For this we will capture your email address and any personal details (such as a name or contact telephone number that you provide) and technical information relating to the IP address from which you sent that email. Any personal data contained in that correspondence will also be retained by us. This also applies to any personal data contained in any email or recorded telephone correspondence we have with our suppliers.
4.6 Where you register to use the public wi-fi available in some of our stores, you will be given the option to consent to receiving marketing communications from us. The marketing we will send to you will be tailored to your interests and behaviours (based on what you buy from us or browse whilst using our wi-fi hotspots). This capability is provided by a third party (see section 5.7) based on the following personal data captured from you (by that third party’s software):
4.7 You are expressly advised that where you login to our public wi-fi hotspots using your social media accounts or Google® profiles, any information contained on that profile may also be transferred to our third party software provider and the information on those profiles will be combined with other information we capture from you during your use of the wi-fi network. Social media behaviours will also be tracked and linked to the targeted marketing you receive.
4.8 We also use your personal data to send you information by email about us, our services and any recent market updates that are similar to those you have already purchased or enquired about, or that we reasonably consider may be relevant to you. We only do this where you have given us permission, and you can opt-out at any time. Where you opt out, we will no longer contact you until you ask us to, and we will not prompt you to do so.
4.9 Our marketing database is hosted, and marketing content is directed, by Fishbowl®, operated by Fishbowl Marketing Limited (a UK registered company with a US corporate parent company). We considered their approach to data processing (prior to their appointment) and were satisfied with how they protect personal data belonging to customers of their clients. Their privacy statement is publicly available at https://www.fishbowl.com/privacy/, in addition to their commitments to GDPR compliance at https://www.fishbowl.com/gdpr-commitment/.
4.10 Fishbowl will host a record of your consent to marketing (including opt-in wi-fi data, specifically date, time, location of IP address), your contact details (including email address and full name), any other information you provide to them (such as dietary requirements or preferences) and your birthday.
4.11 Where you order food from us online (whether for delivery or click and collect), we use a number of online delivery companies to process your order who will initially capture your data and process it in accordance with their privacy policies. They will then pass limited amounts of your personal data to us in order for us to process your order. These include:
5.1 When you use our Website, we will automatically collect technical information about the device you use to visit, including your IP address, browser type/version and related settings. We also monitor your use of our Website. This includes the full URLs, your clickstreams through our Website, the pages you view and how you interact with them and how you leave the Website.
5.3 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer (with your consent). Cookies contain information that is transferred to your computer's hard drive. By continuing to use our Website, you agree to our use of the cookies stated in this section.
5.4 Our Website uses the following cookies:
5.7 We also use third party software to better understand our customers’ needs and behavioural spending habits whilst visiting our stores. Whenever you visit most of our premises, you will be given the option of signing up to use our public wi-fi hotspots. Whenever you use this public wi-fi, third party data analytics software provided by The Wireless Social Group Limited (a UK registered company) is used by us to provide targeted advertisements to you (with your consent) and to analyse customer behaviours within our stores (for performance and management purposes).
5.8 Personal data hosted by Fishbowl is used primarily to run marketing campaigns on our behalf, but also to analyse responses and open rates and investigation of customer queries relating to email receipts or profile updates.
6.1 Your personal data is primarily required to enable us to supply you with the relevant products that you have requested from us, or that we buy from you, and to contact you in relation to any enquiries or requests you raise with us.
6.2 We use analytics information to better understand our customers’ needs and behaviours whilst in our stores, so that we can optimise our business performance and provide relevant advertisements that are appropriate for their interests.
6.3 Technical information we collect about your visit to our Website is used to enable us to:
6.4 We use CCTV at most of our premises for the protection of our staff and property, and for the prevention and detection of crime, and we are registered with the ICO to process your data in this way. All footage is monitored internally by our staff, and retained for up to three weeks (unless required to be retained for longer in connection with the purposes for which it was used). If you visit us at these premises, footage of you will be taken during your time on site and this will be stored and retained by us in accordance with our internal data retention policy.
6.5 Your honest views and feedback, and our performance and service standards are important to us. We will also give you the option of completing a short survey when you sign in to use our wi-fi (provided to you free of charge). Any data captured by these “micro” surveys will be used by us for business management purposes, in line with pursuing our legitimate business interests. We will also ask you to rate our performance in a subsequent micro-survey sent to you by email shortly after your visit. You can opt-out of these at any time (if you wish); we do not need your opt-in consent to ask for your feedback where we do so on a non-invasive basis to pursue our legitimate business needs and interests.
7.2 As we only capture limited amounts of non-sensitive personal data, we do not backup your data our staff are not all trained on their specific obligations under, and your rights in relation to, the Act or the Regulation
7.3 Within Abokado, your data will be processed and analysed by our Marketing Department for the purposes stated in this policy.
7.4 All personal data processed by Fishbowl on our behalf for marketing purposes is accessed by Fishbowl staff only; it is not shared with any other third party.
8.1 Once collected, your personal data will be retained by us for as long as is necessary for us to provide you with the relevant products and to enable us to improve our Website. After this point, the data will be securely deleted.
8.2 Where you are a supplier of member of our staff, your personal data will be retained for the duration of our contract with you, and for up to 6 years following its termination or expiry. This is to ensure we can refer back to your details, should we need to enforce any part of our contract with you.
9.1 In relation to all of your personal data, you have the following rights (in addition to any rights you may have under the Act or the Regulation) to ask us:
9.1.1 not to process your personal data for marketing purposes;
9.1.2 to clarify what data we hold about you, how it was obtained, to whom it has been disclosed and for how long it will be stored;
9.1.3 to amend any inaccurate data we hold about you;
9.1.4 to delete any of your data (where you no longer think we need to hold it, or you think we have obtained or processed it without your consent at any time); and
9.1.5 to only process your personal data in limited circumstances, for limited purposes.
9.2 We have the capacity to extract your personal data from our databases and provide it to you in a structured, commonly-used way (typically by .csv file).
9.3 If you wish to exercise any of your rights at any time, please contact us at firstname.lastname@example.org in the first instance. We will require you to verify your identity to us before we provide any personal data, and reserve the right to ask you to specify the types of personal data to which your request relates.
Where you wish to exercise any of your rights, they may be subject to payment of a nominal administration fee (to cover our costs incurred in processing your request) and any clarification we may reasonably require in relation to your request. Such fees may be charged where we consider (acting reasonably) that your request is excessive, unfounded or repetitive.
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