PRIVACY POLICY

Effective Date: 13 September 2019
Company: Phew Foods Limited ("Phew Foods", "we", "us")

BACKGROUND

At Phew Foods Limited (“Phew Foods”, “we”, “us”) we are committed to protecting your personal information. We also aim at transparency; we want you to know what data we collect about you and how it is used and shared. Please be aware that, whilst we make our best efforts to keep your personal information safe, no Website can be completely secure.

Phew Foods Limited is also devoted to offering you delicious vegan food and drinks (Service).

The following Privacy Policy (“Privacy Policy”) relates to our use of any personal information regarding you that we collect and process via our website, App or other digital network (“Website”) or any other personal information you provide us in person, via email, telephone, text message, or other means in connection with the provision of our Service.

To learn more about your rights to privacy and data protection, we recommend you visit the Information Commissioner’s Office (“ICO”) Website at https://ico.org.uk/.

KEY TERMS

To help you understand the content of our Privacy Policy we have summarised some key terms:

• Data Controller means the individual or organisation that, alone or jointly with others, exercises overall control over how personal data is processed and the purposes of such treatment.
• Communication Methods means email, telephone, notices posted on our Website, or any other communication methods.
• Personal Data means data which relates to a living individual who can be identified from such data, or from data and other information which is in the possession of, or is likely to come into the possession of, the Data Controller.
• Processing means obtaining, recording or holding data or carrying out any operation in relation to Personal Data.
• Third-Party Websites means websites owned and operated by third parties.

DATA CONTROLLER

Phew Foods Limited is a Data Controller. We are responsible for the processing of your personal data in connection with your use of our Website and of the Service.

We are based and operate within the United Kingdom. Our company registration number is 11185436 and our registered office is at 50 Crofton Road, London, United Kingdom, SE5 8NB.

If you have any queries regarding our use of your personal data, please contact us at [email protected]

LEGAL BASIS FOR PROCESSING

We have a legitimate interest in processing your Personal Data. Our legitimate interest includes our commercial interest in offering and providing our services to you.

Furthermore, we may process your Personal Data on the basis that:
 (i) you have consented to such processing; and/or
 (ii) it is necessary for the entry into, or performance of, a contract or in order to take steps at your request prior to the entry into a contract.

INFORMATION WE COLLECT ABOUT YOU

We log your visits and your usage data when you visit our Website. In particular, we use internet protocol (“IP”) addresses, cookies and similar technologies (e.g., web beacons, pixels, ad tags and device identifiers) to identify you or your device. Please read our Cookies Policy to learn more about how we use cookies and similar tracking technologies and how to opt-out.

We receive data from your devices and networks, including location data. When you visit or leave our Website, we receive the URL of both the Website you came from and the one you go to next. We also get information about your IP address, proxy server, operating system, web browser and add-ons, device identifier and features, and/or ISP or your mobile carrier. If you use our Website from a mobile device, that device will send us data about your location. Most devices allow you to prevent location data from being sent to us and we respect your settings.

HOW WE USE YOUR PERSONAL DATA

We may use your Personal Data to give you access to our Website and in particular to:

• provide you with information about our Service;
• contact you through any Communication Method about our Service, provided that you have previously consented to us contacting you;
• produce aggregate insights that do not identify you;
• investigate, respond to and resolve complaints and service issues.

Furthermore, we may collect the following Personal Data:

• UPON REGISTRATION ON OUR WEBSITE – your name, your contact details, your email address, your date of birth, and your current address;
• PROCESSING ONLINE PAYMENTS – the name of the card owner, the card details and the billing address.

RECIPIENTS OF YOUR DATA

To provide and develop our Website, we may share your Personal Data with:

• our subsidiaries, as defined by section 1162 of the Company Act 2006 as amended, extended or re-enacted from time to time, provided that our subsidiaries will be subject to the same terms of this Privacy Policy; and
• third parties for maintenance, analysis, audit, payments, marketing and development.

Third parties will only have access to and use your Personal Data as reasonably necessary to perform these tasks on our behalf and they will be bound to non-disclosure obligations and to the terms of this Privacy Policy.

We may have to disclose your Personal Data if it is reasonably necessary to:

(i) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies;
 (ii) investigate and defend ourselves against any third-party claims or allegations; and
 (iii) protect the security or integrity of our services.

We will attempt to notify you about legal demands for your Personal Data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

We may share your Personal Data as part of a sale, merger or change in control, or in preparation for any of these events.

Any other entity which buys Phew Foods or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy.

DATA RETENTION

We will normally keep your Personal Data for as long as it is necessary to provide you with access to our Website and/or Service and in any case for a maximum of 3 months from the first collection of your Personal Data.

CROSS-BORDER DATA TRANSFERS

We do not transfer, store or process your Personal Data at destinations outside the European Economic Area (“EEA”).

CHANGE TO THIS PRIVACY POLICY

As we are committed to constantly improving our Service, we may change the selection of data and the way we process it.

We reserve the right to change or adapt this Privacy Policy from time to time. Please check our Website to have access to the latest version, as your continued use of our Website and/or Service following any changes will be deemed to be your acceptance of such changes.

THIRD-PARTY ADVERTISERS

We do not share your Personal Data with any third-party advertisers or ad networks.

MARKETING

We do not send you marketing communications unless you have opted-in to receive marketing communications.

To change your marketing preferences, you may also email us at [email protected].

SECURITY

We implement a number of security safeguards designed to protect your data, such as HTTPS. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

YOUR RIGHTS

RIGHT OF ACCESS

We offer you access to the Personal Data we hold about you. Please be aware that the purpose of an access request is to give you the opportunity to confirm the accuracy of Personal Data we are holding about you, the lawfulness of our processing and to allow you to exercise the rights you have in relation to the use of your Personal Data.

We reserve the right to reject manifestly unfounded (e.g. made for other, non-data protection purposes) or excessive requests.

To have access to the Personal Data we store about you, please contact us at: [email protected]

RIGHT TO WITHDRAW CONSENT

Please be aware that, if you have given us consent to process your Personal Data for the purposes detailed in this Privacy Policy, you can always change your mind and withdraw your consent by contacting us at: [email protected]

In order to process your requests, we may ask you to send us a copy of two forms of identification (such as a passport, driving license, birth certificate, bank statement, or utility bills).

FURTHER RIGHTS

You also have the right to lodge a complaint about our processing of your Personal Data and/or our handling of your complaints to ICO or the appropriate data protection authority if you reside outside the United Kingdom.

To learn more about your rights please visit the ICO’s Website at https://ico.org.uk/.