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Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

Key terms

It would be helpful to start by explaining some key terms used in this policy:

We, us, our:   Ghee Appétit Ltd, 1 Barnfield Crescent, Exeter, Devon, EX1 1 QT; Regd. Office : 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ.

Personal information: Any information relating to an identified or identifiable individual.

Personal information we collect about you

We may collect and use the following personal information about you:

  • your name and contact information, including email address and telephone number and company details
  • Information to enable us to check and verify your identity, eg your date of birth
  • location data, if you choose to give this to us
  • your billing information, transaction and payment card information
  • your contact history and purchase history
  • information to enable us to undertake credit or other financial checks on you
  • Information about how you use our website, IT, communication and other systems
  • your responses to surveys, competitions and promotions

How your personal information is collected

We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our website. However, we may also collect information:

  • from publicly accessible sources, eg Companies House or HM Land Registry;
  • directly from a third party, eg:
  • sanctions screening providers.
  • credit reference agencies.
  • customer due diligence providers.
  • from a third party with your consent
  • from cookies on our website—for more information on cookies, please see https://www.allaboutcookies.org
  • via our IT systems, e.g.:
  • automated monitoring of our websites and other technical systems, such as our computer networks and connections, communications systems, email and instant messaging systems.

How and why, we use your personal information

Under data protection law, we can only use your personal information if we have a proper reason for doing so, eg:

  1. to comply with our legal and regulatory obligations. To prevent fraud against you or Ghee Appétit Ltd. Where required due to audits, enquiries or investigations by regulatory bodies. Where required by health & Safety regulations and under other such regulations.
  2. for the performance of our sale contract with you. 2.1 Conducting identity checks for fraud. 2.2 Credit reference checks
  3. For our Policy and Operational needs. 3.1 Preventing unauthorised access to systems. 3.2 Enabling us to manage our business in relation to our financial performance, customer base, product range and other efficiency measures. 3.3 Updating and enhancing customer records. 3.4 Staff Training.                      
  4. for our legitimate interests or those of a third party, or where you have given consent. External audits and quality checks compliance.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

Promotional Communications

We may use your personal information to send you updates (by email, text message, telephone or post) about our products, including exclusive offers, promotions or new products.

We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never share it with other organisations for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

  • contacting us at info@gheeappetit.co.uk
  • using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products in the future, or if there are changes in the law, regulation, or the structure of our business.

Who we share your personal information with?

We routinely share personal information with:

  • third parties we use to help deliver our products to you, e.g. payment service providers, warehouses and delivery companies;
  • other third parties we use to help us run our business, e.g., marketing agencies or website hosts.
  • third parties approved by you, e.g., social media sites you choose to link your account to or third-party payment providers.
  • credit reference agencies.
  • our insurers and brokers.
  • our banks.

We only allow our service providers to handle your personal information if we are satisfied, they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g. in relation to accreditation and the audit of our accounts.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

We will not share your personal information with any other third party.

Where your personal information is held

Information may be held at our offices and those of our third-party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the EEA’.

How long your personal information will be kept

We will keep your personal information while you have an account with us or we are providing products to you. Thereafter, we will keep your personal information for as long as is necessary:

  • to respond to any questions, complaints or claims made by you or on your behalf.
  • to show that we treated you fairly.
  • to keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

Customer and contact data shall be retained for a period of [6] years following the end of our services.

When it is no longer necessary to retain your personal information, we will delete or anonymise it.

Transferring your personal information out of the EEA

To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:

  • with your and our service providers located outside the EEA.
  • if you are based outside the EEA.
  • where there is an international dimension to the services, we are providing to you.

These transfers are subject to special rules under European and UK data protection law.

Non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission.

If you would like further information, please contact us (see ‘How to contact us’ below).

Your rights

You have the following rights, which you can exercise free of charge:

  • The right to require us to correct mistakes in your personal information
  • The right to require us to delete your personal information, in certain situations
  • The right to ask us a copy of your personal information.
  • The right to restrict the processing of your information for direct marketing and profiling.
  • The right not to be subject to a decision based solely on automated processing that produces legal effects.

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

  • email, call or write to us —see below: How to contact us.
  • let us have enough information to identify you (e.g., your full name, address and customer or matter reference number).
  • let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
  • let us know what right you want to exercise and the information to which your request relates.

Keeping your personal information secure

We have appropriate security measures to prevent personal information from being accidentally lost or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We continually test our systems, which means we follow industry standards for information security.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Changes to this privacy policy

This privacy notice is published March 2021.

We may change this privacy notice from time to time—when we do, we will inform you via our website or other means of contact such as email.

How to contact us

Please contact us by post, email or telephone if you have any questions about this privacy policy or the information, we hold about you.

Our contact details are shown below:

Email: info@gheeappetit.co.uk

Telephone: +44 (0) 20 39876725