PRIVACY POLICY & COOKIE POLICY

We take your privacy very seriously. This privacy policy contains important information on how we look after your personal data (regardless of where you are based). It also explains your privacy rights. Our website is not intended for children, and we do not knowingly collect data relating to children.
 
 Controller
 Italicatessen UK Limited is the controller and responsible for your personal data (“we”, “us”, or “our” in this policy). If you have any questions about this privacy policy or our privacy practices, you can contact our data privacy manager in the following ways:
 Italicatessen UK Limited
 Unit 4 Amalgamated Drive
 West Cross Industrial Park
 Brentford London
 TW8 9EZ
 Email: it-support@italicatessenuk.com
 
 Personal data we collect from 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, store, transfer and use different kinds of personal information about you which we have grouped into the following ways:
 •Identity Data includes name, username, marital status, title, date of birth and gender. 
•Contact Data includes business, shipping, billing and delivery addresses; email address and telephone numbers. 
•Financial Data includes bank account and payment card details. 
•Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us. 
•Technical Data includes your internet protocol (IP) address, your login data, device and browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website; 
•Profile Data includes usernames, purchases or orders made by you, your preferences, saved items, 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 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 the contract we have with you, and you fail to provide the data when requested, we may not be able to fulfil the contract we have or are trying to enter with you (for example, to provide you with goods or services). In this case, we may have to cancel an order you have placed with us, but we will notify you if this is the case at the time.
 
 How your personal data is collected
 We use different methods to collect data from and about you including through:
•Direct interactions. You may give us your Identity, Contact or Financial Data in person, by filling in a form, by post, telephone, text or email and via our website. This includes personal data you provide when you: 

1. Place an order for our products or services; 
2. Create an account on our website; 
3. Make an enquiry; 
4. Subscribe to our newsletter or other communications; 
5. Request marketing or other information be sent to you; 
6. Enter a competition, promotion or survey; or 
7. Give us feedback or otherwise contact us.

•Automated interactions. As you interact with our website we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this data by using cookies, server logs and other similar technologies. We may also collect personal data via our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems.

 
•Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below: 

1. Identity and Contact Data from publicly accessible sources, eg Companies House, Electoral Register based in the UK or HM Land Registry; 
2. Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as sanction screening providers, credit reference agencies, customer due diligence providers, banks and building societies. 

 
How and why we use your personal information
 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 comply with our legal and regulatory obligations;
•we need to for the performance of the contract we are about to enter into or have entered into with you or to take steps at your request before entering into a contract;
•it is necessary for our legitimate interests; or
•where you have given consent. Generally we do not rely on consent as a legal basis for processing your personal data other than for marketing. You may withdraw your consent to marketing at any time by contacting us.
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 where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Purposes for which we will use your personal data.
 The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for (purpose/activity)	Type of data	Our reasons – lawful basis for processing
To register you as a new customer	Identity  Contact	Performance of a contract with you

 

To process and deliver your order including:  manage payments, fees and charges  to collect and recover money owed to us	Identity  Contact  Financial  Transaction  Marketing and communications	Performance of a contract with you  Necessary for our legitimate interests (to recover a debt due to us)
To provide sourcing, distribution and delivering a wide range of Italian products and other food services to you (“Services”)	Identity  Contact  Transaction  Profile  Usage	Performance of a contract with you  Necessary for our legitimate interests (to keep our records updates and to understand and meet your requirements)  To take steps at your request before entering a contract
To administer and protect our business and its website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity  Contact  Technical	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent and detect fraud.  Necessary to comply with a legal obligation
Conducting checks to identify our customers and verify their identity	Identity  Contact  Financial  Technical	To comply with our legal and regulatory obligations  For performance of a contract with you

 

Screening for credit worthiness, financial and other sanctions or embargoes	Identity  Contact  Financial  Transaction	To comply with our legal and regulatory obligations  Performance of a contract with you  Necessary for our legitimate interests (to prevent fraud and to ensure payment for goods provided)
Ensuring business policies are adhered to, eg policies covering security and internet use		For our legitimate interests or those of a third party, ie to make sure we are following our own internal procedures so we can deliver the best service to you
Statistical analysis and data analytics to help us manage our business, eg to improve our website, financial performance, customer relationships and experience, product range or other efficiency measures	Technical  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 inform our marketing strategy, so we can deliver the best service for you at the best price
Preventing unauthorised access and modifications to systems		For our legitimate interests or those of a third party, ie to prevent and detect criminal activity that could be damaging for us and for you  To comply with our legal and regulatory obligations
To manage our relationship with you which will include:  notifying you about changes to our terms or privacy policy  keeping our records up to date  asking you to leave a review or take a survey	Identity  Contact  Profile  Usage  Marketing and communications	Performance of a contract with you  To comply with our legal and regulatory obligations  Necessary for our legitimate interests (to keep our records updated, to make sure that we can keep in touch with our customers about existing orders and new products and to study how customers us our products/services)
Marketing our products by delivering advertising and website content to you and making suggestions about products that may be of interest to you  ;  —	Identity  Contact  Technical  Usage  Profile  Marketing and Communications	Necessary for our legitimate interests (to study how customers use out products/ services, to develop them, to promote and grow our business and to develop our offering, to inform marketing strategy)

 
Promotional communications
 We may use your personal information 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 and offers may be relevant for you (we call this marketing).  We may send you updates (by email, text message, telephone or post) about our products and services, including exclusive offers, promotions or new products and services 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 treat your personal information with the utmost respect and never sell it to other organisations for marketing purposes.
 We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
 
 Opting out and preferences
 You have the right to opt out of receiving promotional communications at any time by:
•contacting us at info@italicatessenuk.com
 •using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts
We may ask you to confirm or update your marketing preferences if you place further orders with us , or if there are changes in the law, regulation, or the structure of our business. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, experience or other transactions.
 
 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 our website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.
 
 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.
 
 Who we share your personal information with?
 We may share your personal data with the parties below for the purposes set out in the table above [Purpose for which we will use your personal data]:
•third parties we use to help deliver our goods and services to you, including, IT and system administration providers, payment and financial services providers, couriers and postal services based in the United Kingdom;
 •other third parties we use to help us run our business, such as marketing agencies or website hosts; market researchers; fraud prevention agencies and price comparison sites based in the United Kingdom;
 •HM Revenue & Customs, regulators and other authorities based in the United Kingdom;
 •third parties approved by you, eg social media sites you choose to link your account to or third-party payment providers based in the United Kingdom;
 •credit reference agencies based in the United Kingdom;
 •our professional advisers including lawyers, bankers, accountants, auditors, insurers and brokers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services;
 •third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
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 purpose and in accordance with our instructions.
 
 How long your personal information will be kept
 We will keep your personal information while you have an account with us or we are providing products or services to you. Thereafter, we will keep your personal information for as long as is necessary:
 •to respond to any questions, complaints or claims made by you or on your behalf;
 •to show that we treated you fairly;
 •to keep records required by law.
 We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. When it is no longer necessary to retain your personal information, we will delete or anonymise it.
 
 International transfers
 We do not intend to share your personal information outside the UK. If it is necessary share your personal information with external third parties who are based outside the UK so their processing of your personal data will involve a transfer outside the UK we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
 •We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
 •Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
 If you would like further information, please contact us.
 
 Keeping your personal information secure
 We have appropriate security measures to prevent personal information from being accidentally lost or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
 We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
 
 Data Retention 
 How long will you use my personal data for?
 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. [Details of retention periods for different aspects of your personal data are [available in our retention policy which you can request from us by contacting us].
 
 Your rights
 Under certain circumstances, you have the rights under data protection laws in relation to your personal data.

Request Access	The right to be provided with a copy of the personal data we hold about you and to check that we are lawfully processing it (commonly known as a “data subject access request")
Request rectification/correction	The right to request that we correct any mistakes in your personal data that we hold about you.  This enables you to have any incomplete or inaccurate data we hold about you corrected, though you may need to verify the accuracy of the new data you provide to us.
Request erasure (To be forgotten)	This enables you to ask us to delete or remove your personal data where there is no good reason for us to 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 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.
Restriction of processing	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.
Data portability/ transfer request	You can 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 and 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.
To object to processing	You have the right to object to processing 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.
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.

 
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 within 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.
 
 For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
 
 How to complain
 We hope that we can resolve any query or concern you may raise about our use of your information. The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
 
 Changes to this privacy policy
 We may change this privacy notice from time to time—when we do we will inform you via our website.