PRIVACY POLICY OF OKAY CHEF LIMITED

DATED: 29th May 2020

Introduction

Welcome to the privacy policy of Okay Chef Limited (company number 12567970) of 337 Bath Road, Slough, SL1 5PR (collectively referred to as “we”, “us” and “our” in this privacy policy).

We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website available at www.okaychef.co.uk (the “Site”) and use our mobile application available via our Site (the “App”), regardless of where you visit and use them from, and tell you about your privacy rights and how the law protects you. If you have downloaded our App you will be invited to consenting to us collecting and processing your personal data through your use of our App in accordance with this privacy policy. You can withdraw your Consent at any time by contacting us.

You can download a pdf version of the policy here: [pdf version]. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

Important Information and Who We Are

Purpose of this privacy policy

This privacy policy aims to give you information on how we collect and process your personal data through your use of our Site and our App, including any data you may provide through our Site or App when you sign up to our newsletter.

Our Site and App are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy 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 policy supplements other notices and privacy policies and is not intended to override them.

Controller

We are the controller and responsible for your personal data we collect through your use of our Site and App.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise, please contact the DPO using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

Full name of legal entity: Okay Chef Limited

Name of DPO: Robert Daniel Hutt

Email address: dpo@okaychef.co.uk

Postal address: 337 Bath Road, Slough, SL1 5PR

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on the date set out at the top of this privacy policy. We will notify you of any material changes by pop-up on our Site or App (as applicable). Historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Our Site and App 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 Site and App, we encourage you to read the privacy policy of every website and application you visit.

The Data We Collect About 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, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature on our Site or App. 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 policy.

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 a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract.

How Is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

How We Use Your Personal Data

We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:

See our Glossary, Lawful Basis to find out more about the types of Lawful Basis that we will rely on to process your personal data.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our Legitimate Interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interest
To enable you to apply for our products or services and register you as a new customer  (a) Identity (b) Contact(a) Consent (b) Performance of a Contract
To enable you to use our Site or App, purchase products or services via our Site or App and subscribe to our services or publications(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (f) Location(a) Consent   (b) Performance of a Contract (c) Necessary for our Legitimate Interests (to study how customers use our Site or App and our products or services, to develop them and to grow our business)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you give us feedback, leave a review or take a survey(a) Identity (b) Contact (c) Profile (d) Marketing and Communications(a) Consent (b) Performance of a Contract (c) Necessary to Comply with a Legal Obligation (d) Necessary for our Legitimate Interests (to keep our records updated and to study how customers use our Site or App and our products or services)
To enable you to partake in a prize draw, competition, promotion or complete a survey(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications(a) Consent (b) Performance of a Contract (c) Necessary for our Legitimate Interests (to study how customers use our Site or App and our products or services, to develop them and grow our business)
To administer and protect our business and our Site and App (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)(a) Identity (b) Contact (c) Technical(a) Necessary for our Legitimate Interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to Comply with a Legal Obligation
To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical (g) Location(a) Consent (b) Necessary for our Legitimate Interests (to study how customers use our Site or App and our products or services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Site or App, products or services, marketing, customer relationships and experiences(a) Technical (b) Usage(a) Consent (b) Necessary for our Legitimate Interests (to define types of customers for our Site or App and our products or services, to keep our Site and App updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications (g) Location  (a) Consent (b) Necessary for our Legitimate Interests (to develop our Site or App and our products or services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data 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, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased or subscribed for goods or services via our Site or App and you have consented to receiving that marketing.

Third-party marketing

We will get your Consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the Site or App and checking or unchecking relevant boxes to adjust your marketing preferences, by following the opt-out links on any marketing message sent to you or by contacting us at any time.

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 or service purchase, experience or other transactions.

PUSH NOTIFICATIONS

You will receive push notifications from us via our App if you have downloaded our App and you have consented to receiving those push notifications. You can withdraw your Consent at any time by disabling push notifications in relation to our App in your settings or by contacting us.

Cookies

We use cookies to distinguish you from other users of the Site or App, and to remember your preferences. This helps us to provide you with a good experience when you use our Site or App and also allows us to improve the Site and App. For more information about the cookies we use, please see our cookie policy [■link to 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.

Disclosures of Your Personal Data

We may share your personal data with the parties set out below for the purposes set out in the table above.

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

Some of our External Third Parties may be based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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.

Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Site or App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

We have put in place procedures 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.

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.

In some circumstances you can ask us to delete your data: please see Your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your Legal Rights

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data, as set out below:

If you wish to exercise any of the rights set out above, please contact our DPO.

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.

Glossary

LAWFUL BASIS

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent 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 or 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 for activities where our interests are overridden by the impact on you (unless we have your Consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of a Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a Legal Obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Other companies in our group acting as joint controllers or processors and who may provide IT and system administration services and undertake leadership reporting.

External Third Parties