- Introduction and who we are.
This policy sets out Happy Curations Ltd (“Company,” “we,” “us” or “our”) policies regarding the collection, use and disclosure of personal data when you use our unrooteddrinks.com website (“Website”) and the choices you have associated with that data.
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we will take steps to remove that information from our servers.
For the purpose of the Data Protection Act 2018, the data controller is Happy Curations Limited whose registered office is at Floor 4, 15-19 Great Titchfield Street, London, W1W 8AZ.
It is important that the personal data we hold about you is accurate and current, so please keep us informed if your personal data changes.
- The data we collect
To provide you with the products we offer, we request specific personal information (personal data) as detailed below. We value and respect your privacy.
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
We may collect, use store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity data: includes first name, last name, usernames or similar identifier, title, date of birth
Contact data: includes billing address, delivery address, email address and telephone numbers
Transaction data: includes details about payments to and from you and other details of products you have purchased from us
Technical data: includes your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Profile data: includes purchaser or orders made by you, your interests, preferences, feedback and survey responses
Usage data: data collected automatically either generated by the use of the Website or from the Website infrastructure itself, including how you use our website and products.
Marketing and Communications data: includes your preferences in receiving marketing from us and third parties and your communication preferences
While using our Website, we may ask you to provide us these different types of Personal Data as well as aggregated data such as statistical or demographic data. This is not considered personal data by law as it does directly or indirectly reveal your identity.
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions in any email we send.
- How We Collect Your Personal Data.
We collect personally identifiable information using different methods, including the following:
- Direct interactions. You may give us your Identity and Contact Data by filling in forms or corresponding with us, including when you:
- purchase our products.
- Create an account on our website
- Request marketing to be sent to you
- Enter a competition, promotion or survey
- Give us some feedback.
- Automated technologies or interactions. When you engage with the Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs or similar.
- Third party or publicly available sources. We may receive personal data about you from other sources as set out below:
- Technical Data from analytics providers (such as Google based outside the EU), advertising networks and search information providers.
- Contact and Transaction Data from providers of technical, payment and delivery services.
- Identify and Contact Data from data brokers or aggregators
- Identity and Contact Data from publicly available sources (such as Companies House).
- How We Use Your Personal Information and Personal Data.
We will only process and use personal data for the following reasons or in the following ways:
- For our market research purposes.
- To provide, maintain and improve our Website.
- To notify you about changes to our Website.
- To allow you to participate in interactive features of our Website when you choose to do so.
- To provide customer support.
- To monitor the usage of our Website.
- To detect, prevent and address technical issues.
- To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
- To provide Products and services that you request.
- Process, validate, confirm, verify, deliver and track your purchases, arranging shipping and handling returns and refunds, and contacting you about your orders, including by telephone).
- Maintain a record of the purchases you make.
- Tailor our Products and services to suit your personal interests and manner in which you use the Website.
- Analyse and enhance our marketing communications and strategies.
- Analyse trends and statistics regarding the user experience when visiting the Website, mobile applications or social media assets, and the purchases you make.
- We need to send the information to third party partners, vendors, agents, or service providers who provide a Product or service for you on our behalf and to provide other related services, including, but not limited to, payment processing, shipping, order tracking, promotional fulfilment, and customer service.
- We may also exchange information, including personally identifiable information, with other companies and organisations for credit fraud protection and risk reduction.
- For any other purpose or use, provided we have your consent.
We will get your express opt-in consent before we share your personal data with any third party. We may use your personal data for marketing communications if you have requested information from us or if you have purchased goods from us and you have not opted out of receiving that marketing. If you do not want us to use your personal information for our marketing purposes, send us an email at email@example.com stating that you withdraw your consent to such use.
- Legal Basis for Processing Personal Data
We will only use your Personal Data where the law allows us to. Mostly commonly, this is because:
- We need to perform a contract with you
• You have given us permission to do so and have not withdrawn that permission
• The processing is in our legitimate interests (or those of a third party) and it’s not overridden by your interests and fundamental rights
• To comply with the law or other regulatory obligation
- Retention of Data.
We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Website, or we are legally obligated to retain this data for longer time periods.
In certain circumstances you can ask us to delete your personal data: see section 10 below.
- Transfer of Data.
We do not transfer your personal data outside the European Economic Area (EEA).
- Disclosure of Data.
We may disclose your Personal Data with the parties set out below for the purposes set out in section 4 above:
- Other companies in the Happy Curations Ltd group
- Service providers acting as processors based in the UK who provide IT and system administration services;
- Payment providers, such as Stripe;
- Professional advisers including lawyers, accountants, bankers and auditors;
- HMRC, regulators and other authorities;
- Third party service providers which provide the Website on our behalf, perform Website-related services or assist us in analysing how our Website is used;
- Third parties who provide delivery & courier services in relation to our online shop
- Third parties to whom we may sell, transfer or merge parts of our business or our assets.
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.
- Security of Data.
The security of your personal data is important to us and we have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed without authorisation, altered or disclosed. However, remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
We have put in place measures 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.
- Your Data Protection Rights
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us on firstname.lastname@example.org.
In certain circumstances, you have the following data protection rights:
The right to access. Commonly known as a data subject access request, you have the right to receive a copy of the personal data we hold about you and to check that we are lawfully process it.
The right to request erasure. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it or if you have successfully exercised your right to object to processing, where we have processed your information unlawfully or where we are required to erase your personal data to comply with local law. We may not always be able to comply with your request if there are specific legal reasons.
The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
The right to object. You have the right to object to our processing of your Personal Data where we are processing it for direct marketing purpose or where we are relying on a legitimate interest and you feel it impacts your fundamental rights and freedoms.
The right of restriction. You have the right to request that we restrict the processing of your personal information (a) if you want us to establish the data’s accuracy, (b) where our use of the data is unlawful but you don’t want us to erase it, (c) where you need us to hold the data even if we no longer need it as you need it in relation to legal claims, and (d) you have objected to our of your data but we need to check if we have overriding legitimate grounds to use it.
The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
The right to withdraw consent. You also have the right to withdraw your consent at any time where relied on your consent to process your personal information.
Please note that we may ask you to verify your identity or complete other security checks before responding to such requests. We try to respond to legitimate requests within one month, but occasionally it may take us longer. We will keep you updated. Although there is no fee to access personal data, if your request is clearly unfounded, repetitive or excessive, we may either refuse to comply or charge a reasonable fee.
You have the right to complain to the Information Commissioner’s Office about our collection and use of your Personal Data. For more information see www.ico.org.uk or your local data protection authority if outside the UK.