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GDPR DATA Privacy notice for websites
This Privacy Notice sets out the basis on which we will process the personally identifying information (‘Personal Data’) that we collect and receive from and about users of our websites (www.chambersofflavour.co.uk, www.flavourology.co.uk, www.gingerline.co.uk, www.junipermanor.com, www.grandexpedition.co.uk) (together “the Sites”) and customers who purchase tickets for our events, attend our events, subscribe to our newsletters, or engage our services.
OUR PRIVACY COMMITMENTS
We will only collect, keep, use and share Personal Data for legitimate business purposes that we explain here below, or if we’re legally required to do so.
We will be as clear and open as we can with you on what Personal Data we collect and how it will be processed.
For as long as we maintain records of your Personal Data, we will keep it up to date and protect it with appropriate safety measures.
PURPOSE OF THIS NOTICE
The purpose of this privacy notice is to inform you as to how we look after your personal data (regardless of how we obtain it). We’ll also tell you about your privacy rights and how the data protection law protects you.
This website is not intended for children and we do not knowingly collect data relating to children.
You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
DATA CONTROLLER(S)
Gingerline Ltd and Gingertown Ltd are the controllers and responsible for your personal data (collectively referred to as "COMPANY", "we", "us" or "our" in this privacy notice). Our contact details are; registered address IBEX House, 162-164 Arthur Road, Wimbledon, London, SW19 8AQ, gingerliners@gingerline.co.uk, Arches 210-212, Edward St. London, SE8 5TD. For all data matters contact our Data Privacy Manager, Davy Berryman, on davy@gingerline.co.uk.
Third-party links outside of our control
The Sites 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. Details of the third parties we link with are outlined further down this notice.
THE PERSONAL DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows.
CUSTOMERS
Data Collection
We collect the following Personal data from or about you as a Customer who uses our event and/or catering services
- Personal Data Collected Directly from you through the booking process: your name, phone number, company address, email address. Our legal basis for the collection and processing of this data is the provision to you of the services purchased by you.
- Personal Data Collected Automatically from the use by you of the Sites. The data transmitted from your browser includes your IP address, the date and time of the visit the pages accessed, the access status/HTTP status code, your browser, your operating system and interface, as well as the language and version of the browser software. The legal basis for collecting and processing this personal data is to be able to operate the Sites and provide you with access to the pages you wish to access.
Data Uses
We use your Personal Data:
- For the design, development and execution of your bespoke event and to contact you about the event and any future events you may want to hold.
- To contact you with marketing messages which you have requested or agreed to receive from us (for example via a branded newsletter);
EVENT GUESTS
Data Collection
We collect the following data from you as an event guest:
- Personal Data Collected Directly: your title, name, email address, mobile phone number, city where you live, food allergies and intolerances, and mobility requirements - during the ticket purchasing process. Our legal basis for the collection and processing of this data is the provision to you of the services purchased by you.
- Personal Data Collected Indirectly: your attendance history. Our legal basis for collecting and processing this personal data is our legitimate interests in knowing more about our customers.
- Personal Data Collected Automatically from the use by you of the Sites. The data transmitted from your browser includes your IP address, the date and time of the visit the pages accessed, the access status/HTTP status code, your browser, your operating system and interface, as well as the language and version of the browser software. The legal basis for collecting and processing this personal data is to be able to operate the Sites and provide you with access to the pages you wish to access.
Data Uses
We use your Personal Data:
- To contact you about your attendance (for example with your arrival time and secret location) and the menu you will be experiencing on the day.
- To contact you with future event marketing messages (for example with upcoming event information, and newsletters);
- To send you surveys or feedback requests (for example after you attended an event);
- To find out more about our guests and their preferences (for example by analysing your attendance history).
SOCIAL MEDIA FOLLOWERS
Data Collection
We receive the following Personal Data about you if you follow one of our social media accounts: Your account name, gender, general interests, location, age. Our legal basis for processing this data is our legitimate interest in providing social media and marketing content that is of interest to our followers on social media.
Data Uses
We use your Personal Data:
- To provide bespoke social media content (for example by analysing your general interests);
- To create targeted advertising across all our social media channels (for example by analysing responses to posts and existing advertisements);
- To find out more about our digital community (for example by analysing the age ranges of our followers).
WEBSITE VISITORS
Data Collection
We collect the following Personal Data about you if you visit one of our Sites: site referrals, browsing pattern, browser type, location, general interests, gender, age. The data transmitted from your browser includes your IP address, the date and time of the visit the pages accessed, the access status/ HTTP status code, your browser, your operating system and interface, as well as the language and version of the browser software. The legal basis for collecting and processing this personal data is our legitimate interest in operating the Sites, providing you with access to the pages you wish to access, understanding the interests of our potential customers and providing you with relevant information about our services.
Data Uses
We use this Personal Data:
- To provide you with bespoke website content (for example by analysing our site visitors’ age ranges); to gain insight into your behaviour and preferences (for example by analysing the website pages you visit);
- To create bespoke marketing messages (for example by analysing the click throughs on our Sites);
- To collect site statistics.
FACEBOOK PIXELS
We use Facebook pixels on our pages. Pixels are lines of code placed on our website to help us track conversions from Facebook ads, optimise ads based on collected data, and build targeted audiences.
GOOGLE ANALYTICS
Google Analytics, a web analytics service provided by Google, Inc. (“Google”) also places cookies on your computer, to enable Google to provide us with activity reports relating to the Sites. Google uses this data only to provide us with information on how users use the Sites and does not associate your IP address with any other data held by Google. The information generated by Google cookies about your use of the platform (including your IP address) will be transmitted to and stored by Google on servers in the United States. You may refuse these cookies by selecting the appropriate settings on your browser or by downloading and installing the browser plug-in available under https://tools.google.com/dlpage/gaoptout?hl=en-GB.
OTHER CATEGORIES OF DATA
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
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 your personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product purchased or service you have with us but we will notify you if this is the case at the time.
MARKETING
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and if you have not opted out of receiving that marketing.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Opting Out
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
- By following the opt-out links on any marketing message sent to you
- By un-following us on any of our Social Media profiles
- By responding to any emails from our team asking to ‘Opt Out’ of any correspondance
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, product or service experience or any other similar transactions.
Third-Party Marketing
We will get your express opt-in consent before we share your personal data with any company outside the Company for marketing purposes. However, the Company want you to know that Gingerline is not in the business of selling, renting or trading email lists with other companies and businesses for marketing purposes.
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 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 DATA WITH
The Company will not sell your information. We will not share your information with any third party except as stated in this Privacy Notice or as required to operate the Sites and provide our services to you.
We use third party processors to collect, export, process and store Personal Data on our behalf. The processors we use currently are the following:
Ticket Seller: Eventbrite, some data centres located in the U.S. Privacy Shield Certified. https://www.eventbrite.co.uk/support/articles/en_US/Troubleshooting/eventbrite-privacy-policy?lg=en_GB
Payment Processor: Paypal, https://www.paypal.com/ee/webapps/mpp/ua/privacy-full
CRM Tool: Mailchimp, https://kb.mailchimp.com/accounts/management/about-mailchimp-the-eu-swiss-privacy-shield-and-the-gdpr
Cloud Storage: Sugarsync, https://www2.sugarsync.com/privacy
Email host: 1and1 https://www.1and1.co.uk/terms-gtc/terms-privacy/?linkId=ft.nav.privacypolicy
Social Media Platform: Facebook, some data centres located in the U.S. Privacy Shield Certified. https://www.facebook.com/privacy/explanation, Twitter https://twitter.com/en/privacy, Instagram https://help.instagram.com/519522125107875, LinkedIn https://www.linkedin.com/legal/privacy-policy
Survey Tool: Google Forms https://policies.google.com/privacy?hl=en&gl=uk
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.
INTERNATIONAL TRANSFERS
We use data processors located outside the European Economic Area only after taking such steps as are required to ensure that Personal Data they process on our behalf receives protection equivalent to that provided in the EEA. Our processors are either certified as compliant with the EU-U.S. Privacy Shield Framework where they are located in the USA or have entered into an agreement with us containing the model clauses approved by the European Commission as providing contractual protection equivalent to that provided by the data protection regulations applicable in the EEA. To learn more about the Privacy Shield program, please visit www.privacyshield.gov .
DATA SECURITY
We maintain technical and physical safeguards that are designed to protect the security and integrity of your Personal Data, and to guard it against accidental or unauthorised access, use, alteration or disclosure to unauthorised third parties. These measures include device encryption, firewalls and virus checking procedures.
Where we keep Personal Data files on local devices these devices are protected and accessible only to authorised Company employees, and contractor.
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. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We regularly review our security systems to ensure that your Personal Data remains safe and secure.
DATA RETENTION
We will maintain records of your Personal Data for as long as you remain:
- A customer
- A registered subscriber to our mailing lists;
- A follower of our profiles on social media platforms
- A visitor to one of our websites
- Have completed a purchase through one of our Sites
- For as long as is necessary to provide our services to you.
We will where possible 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.
In some circumstances you can ask us to delete your data: see ‘Your legal rights’ below for further information.
In regards to aggregated data, for example where we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary to retain such data;
- The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable 9i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).
If you wish to exercise any of the rights set out above, please contact our Data Privacy Manager, Davy Berryman, on davy@gingerline.co.uk.
No fee required – with some exceptions
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 admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may 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 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.
Changes to this notice and your duty to inform us of changes
This version was last updated on 8 August, 2018
Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.
Queries, requests or concerns
To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact our please contact our Data Privacy Manager, Davy Berryman, on davy@gingerline.co.uk.
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK.