As you may know the GDPR (General Data Privacy Regulation) has come into force on the 25th May, 2018. At the Paella Company we truly welcome this new legislation as we are committed in ensuring the best possible service to our customers and that includes what personal data we keep and the reasons why we need that data.
The Paella Company Ltd is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
2. WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT
Personal data means any information capable of identifying an individual. It does not include anonymised data. We may process the following categories of personal data about you:
- Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
- Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground 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.
- Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our events and projects. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy. We may use Customer Data and Marketing Data to deliver relevant website content to you and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests, which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).
- Sensitive Data We do not collect any Sensitive Data about you. Sensitive data refers to data that 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. We do not collect any information about criminal convictions and offences.
3. HOW WE COLLECT YOUR PERSONAL DATA
We may collect data about you by you providing the data directly to us (for example by filling in forms or by sending us emails). We may also receive data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
4. MARKETING COMMUNICATIONS
Our lawful ground of processing your personal data to send you marketing communications is either only through your explicit consent or our legitimate interests (namely to grow our business). Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if
(i) you made a purchase or asked for information from us about our goods or services or
(ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since.
Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time.
The Paella Company will not share data with any third party. If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as account registrations, purchases etc
5. DISCLOSURES OF YOUR PERSONAL DATA
We may need to share your personal data with the parties set out below:
- Partnership organisations who provide services to us, These include card processing services such as SagePay & Paypal and courier services such as UKMail, Royal Mail, MyHermes and freight delivery providers.
- Website Service providers who provide support services for our website platform.
- Professional advisers including accountants, auditors, & banks
- Government bodies that require us to report processing activities. Third parties to whom we sell, transfer, or merge parts of our business or our assets. We require all parties above 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 the parties named above to process your personal data for specified purposes and in accordance with our instructions. 6. INTERNATIONAL TRANSFERS Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria. None of our third parties service providers are based outside the European Economic Area (EEA). 7. DATA SECURITY We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential. We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to. 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. When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements. For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers. 9. YOUR LEGAL RIGHTS Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent. You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ If you wish to exercise any of the rights set out above, please email us at firstname.lastname@example.org. 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 or 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. 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. 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.