The Bow Window Cafe understands that your privacy is important to you and that you care about how your personal data is used. [We] OR [I] respect and value the privacy of everyone who visits this website, www.thebowwindowcafe.co.uk (“[Our] OR [My] Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with [our] OR [my] obligations and your rights under the law.
- Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
|“Account”||means an account required to access and/or use certain areas and features of [Our] OR [My] Site;|
|“Cookie”||means a small text file placed on your computer or device by [Our] OR [My] Site when you visit certain parts of [Our] OR [My] Site and/or when you use certain features of [Our] OR [My] Site. Details of the Cookies used by [Our] OR [My] Site are set out in Part 14, below; and|
|[“Cookie Law”||means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;]|
- Information About [Us] OR [Me]
[Our] OR [My] Site is [owned and] operated by The Bow Window Cafe.
[Registered address: The Square, Lenham, Kent, ME17 2PG.]
[Main trading address:] OR [Address:] The Square, Lenham, Kent, ME17 2PG.]
[Data Protection Officer: Cem.
Email address: [email protected]
Company No: 12305975
Telephone number: 01622 850802.
Postal address: The Square, Lenham, Kent, ME17 2PG.]
Email address: [email protected]
Telephone number: 01622 850802.
Postal address: The Square, Lenham, Kent, ME17 2PG.]
[[We are] OR [I am] regulated by General Data Protection Regulation.]
- What Does This Policy Cover?
- What Is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
- What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which [we] OR [I] will always work to uphold:
- The right to access the personal data [we] OR [I] hold about you. Part 13 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by [us] OR [me] is inaccurate or incomplete. Please contact [us] OR [me] using the details in Part 15 to find out more.
- The right to be forgotten, i.e. the right to ask [us] OR [me] to delete or otherwise dispose of any of your personal data that [we] OR [I] Please contact [us] OR [me] using the details in Part 15 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to [us] OR [me] using your personal data for a particular purpose or purposes.
- The right to withdraw consent. This means that, if [we are] OR [I am] relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- The right to data portability. This means that, if you have provided personal data to [us] OR [me] directly, [we are] OR [I am] using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask [us] OR [me] for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. [[We] OR [I] do not use your personal data in this way.]
For more information about [our] OR [my] use of your personal data or exercising your rights as outlined above, please contact [us] OR [me] using the details provided in Part 15.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data [we] OR [I] hold about you changes, please keep [us] OR [me] informed as long as [we] OR [I] have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about [our] OR [my] use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
[We] OR [I] would welcome the opportunity to resolve your concerns [ourselves] OR [myself], however, so please contact [us] OR [me] first, using the details in Part 15.
- What Data Do You Collect and How?
Depending upon your use of [Our] OR [My] Site, [we] OR [I] may collect and hold some or all of the personal [and non-personal] data set out in the table below, using the methods also set out in the table. [[We] OR [I] do not collect any [‘special category’ or ‘sensitive’ personal data] AND/OR [personal data relating to children] AND/OR [data relating to criminal convictions and/or offences].]
|Data Collected||How [We] OR [I] Collect the Data|
Information you supply to us. You may supply us with information about you by filling in forms on our website. This includes information you provide when you submit a contact/enquiry form [list any other active forms on your website (ie. Request an appointment Form, Request a Quote Form, Contact Form, Request a callback Form. The information you give us may include your name, address, e-mail address and phone number, [list any other types of information you collect via other active forms on your website (ie. your name, your date of birth, etc.)].
|Forms, Email, other communication methods.|
Information our website automatically collects about you. With regard to each of your visits to our website we may automatically collect information including the following:
· technical information, including a truncated and anonymised version of your Internet protocol (IP) address, browser type and version, operating system and platform;
· information about your visit, including what pages you visit, how long you are on the site, how you got to the site (including date and time); page response times, length of visit, what you click on, documents downloaded and download errors.
|Google Analytics, Facebook Pixel.|
- How Do You Use My Personal Data?
Under the Data Protection Legislation, [we] OR [I] must always have a lawful basis for using personal data. The following table describes how [we] OR [I] [will] OR [may] use your personal data, and [our] OR [my] lawful bases for doing so:
|What Data [We] OR [I] Use||[Our] OR [My] Lawful Basis|
Information you supply to us.
|to provide you with information and/or services that you request from us;|
Information we automatically collect about you.
· to administer our site including troubleshooting and statistical purposes;
· to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
· security and debugging as part of our efforts to keep our site safe and secure.
[With your permission and/or where permitted by law, [we] OR [I] may also use your personal data for marketing purposes, which may include contacting you by [email] AND/OR [telephone] AND/OR [text message] AND/OR [post] with information, news, and offers on [our] OR [my] [products] AND/OR [services]. You will not be sent any unlawful marketing or spam. [We] OR [I] will always work to fully protect your rights and comply with [our] OR [my] obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.] [[We] OR [I] will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.]
[We] OR [I] will only use your personal data for the purpose(s) for which it was originally collected unless [we] OR [I] reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If [we] OR [I] do use your personal data in this way and you wish [us] OR [me] to explain how the new purpose is compatible with the original, please contact [us] OR [me] using the details in Part 15.
If [we] OR [I] need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, [we] OR [I] will inform you and explain the legal basis which allows [us] OR [me] to do so.
In some circumstances, where permitted or required by law, [we] OR [I] may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights
- How Long Will You Keep My Personal Data?
[We] OR [I] will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
|Type of Data||How Long [We] OR [I] Keep It|
|ALL DATA COLLECTED||NO SET LENGTH|
- How and Where Do You Store or Transfer My Personal Data?
[[We] OR [I] will [only store or transfer your personal data] OR [store or transfer some of your personal data] within the UK. This means that it will be fully protected under the Data Protection Legislation.]
[[We] OR [I] will [only store or transfer your personal data] OR [store or transfer some of your personal data] within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the Data Protection Legislation, GDPR, and/or to equivalent standards by law.]
[[We] OR [I] [may] store or transfer some or all of your personal data in countries that are not part of the [European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein)] OR [EEA]. These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that [we] OR [I] will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:
[[We] OR [I] share your data within the group of companies of which [we are] OR [I am] a part. Where this involves the transfer of personal data outside the EEA, [our] OR [my] group ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage. These are known as “binding corporate rules”. More information on binding corporate rules is available from the European Commission.]
[[We] OR [I] share your data with external third parties, as detailed below in Part 10, that are based outside of the EEA. The following safeguard[s] [is] OR [are] applied to such transfers:
[[We] OR [I] [will only] transfer your personal data to third countries whose levels of data protection are deemed ‘adequate’ by the European Commission. More information is available from the European Commission.]
[[We] OR [I] use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts require the same levels of personal data protection that would apply under the Data Protection Legislation. More information is available from the European Commission.]
[Where [we] OR [I] transfer your data to a third party based in the US, the data may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission.]]
Please contact [us] OR [me] using the details below in Part 15 for further information about the particular data protection mechanism[s] used by [us] OR [me] when transferring your personal data to a third country.]
The security of your personal data is essential to [us] OR [me], and to protect your data, [we] OR [I] take a number of important measures, including the following:
- limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
- procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where [we are] OR [I am] legally required to do so;
- Do You Share My Personal Data?
[[We] OR [I] will not share any of your personal data with any third parties for any purposes, subject to the following exception[s].
In some limited circumstances, [we] OR [I] may be legally required to share certain personal data, which might include yours, if [we are] OR [I am] involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.]
- How Can I Control My Personal Data?
- In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via [Our] OR [My] Site, you may be given options to restrict [our] OR [my] use of your personal data. In particular, [we] OR [I] aim to give you strong controls on [our] OR [my] use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from [us] OR [me] which you may do by unsubscribing using the links provided in [our] OR [my] emails [and] OR [,] at the point of providing your details [and by managing your Account]).
- You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
- Can I Withhold Information?
You may access [certain areas of] [Our] OR [My] Site without providing any personal data at all. [However, to use all features and functions available on [Our] OR [My] Site you may be required to submit or allow for the collection of certain data.]
- How Can I Access My Personal Data?
If you want to know what personal data [we] OR [I] have about you, you can ask [us] OR [me] for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. [To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell [us] OR [me] everything [we] OR [I] need to know to respond to your request as quickly as possible.]
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover [our] OR [my] administrative costs in responding.
[We] OR [I] will respond to your subject access request within [less than one month and, in any case, not more than] one month of receiving it. Normally, [we] OR [I] aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date [we] OR [I] receive your request. You will be kept fully informed of [our] OR [my] progress.
All Cookies used by and on [Our] OR [My] Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a pop up banner on first visit requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling [us] OR [me] to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of [Our] OR [My] Site may not function fully or as intended. [You will be given the opportunity to allow only first-party Cookies and block third-party Cookies.]
[Certain features of [Our] OR [My] Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that [Our] OR [My] Site may not work properly if you do so. [We] OR [I] have taken great care to ensure that your privacy is not at risk by allowing them.]
- How Do I Contact You?
To contact [us] OR [me] about anything to do with your personal data and data protection, including to make a subject access request, please use the following details [(for the attention of Cem)]:
Email address: [email protected]
Telephone number: 01622 850802.
Company No: 12305975.
Postal Address: The Square, Lenham, Kent, ME17 2PG.
[We] OR [I] may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if [we] OR [I] change [our] OR [my] business in a way that affects personal data protection.