Privacy and Data Protection Policy
This Privacy Policy sets out how we, Scunny Eats trading under the name Cube Incorporated, collect, store and use information about you when you use or interact with our website, www.scunnyeats.co.uk (our website) and where we otherwise obtain or collect information about you. This Privacy Policy is effective from 1/7/2023
Summary
This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.
How we collect or obtain information about you
When you provide it to us (e.g. by placing an order on our website or creating an account.
from your use of our website, using cookies and similar technologies and
occasionally, from third parties.
Information we collect
Name, contact details, IP address, information from cookies, information about your computer or device (e.g. device and browser type), information about how you use our website (e.g. which pages you have viewed, the time when you view them and what you clicked on, the geographical location from which you accessed our website (based on your IP address)
How we use your information
For administrative and business purposes particularly to contact you and process orders you place on our website, to improve our business and website, to fulfil our contractual obligations, to advertise our goods and services and to analyse your use of our website.
Disclosure of your information to third parties
Only to the extent necessary to complete our services e.g. providing information to our partnered stores. Do we sell your information to third parties other than in the course of a business sale or purchase or similar event? No!
How long do we retain your information
For no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information.
How we secure your information
Using appropriate technical and organisational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology, encrypting payments you make on or via our website using Secure Sockets Layer (SSL) technology.
Transfers of your information outside the European Economic Area
We will NOT transfer your data outside of the European economic area, unless for the purpose of our service and if "Scunny Eats” expands its services to areas outside of the EEA.
Your rights in relation to your information
To access your information
To receive information about its use
To have your information corrected and/or completed
To have your information deleted to restrict the use of your information
To receive your information in a portable format
To object to the use of your information
To withdraw your consent to the use of your information
To complain to a supervisory authority
Sensitive personal information
We do not knowingly or intentionally collect what is commonly referred to as ‘sensitive personal information’. Please do not submit sensitive personal information about you to us.
Our details
The data controller in respect of our website is Cube Incorporated Limited, company registration number: 13758428
You can contact the data controller by writing to 19 Charterhouse Drive, Scunthorpe, North Lincolnshire, United Kingdom, DN16 3QP
If you have any questions about this Privacy Policy, please contact the data controller.
Information we collect when you visit our website
We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.
Web server log information
Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating system.
Use of website server log information for IT security purposes
Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.
Legal basis for processing
Compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation
We have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.
Legitimate interests
We have a legitimate interest in using your information for the purposes of ensuring network and information security. Use of website server log information to analyse website use and improve our website. We use the information collected by our website server logs to analyse how our website users interact with our website and its features. For example, we analyse the number of visits and unique visitors we receive, the time and date of the visit, the location of the visit and the operating system and browser used.
We use the information gathered from the analysis of this information to improve our website. For example, we use the information gathered to change the information, content and structure of our website and individual pages based according to what users are engaging most with and the duration of time spent on particular pages on our website.
Information we collect when you contact us
We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.
When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).
Legal basis for processing
Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s)
Responding to enquiries and messages we receive and keeping records of correspondence.
Legal basis for processing
Necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract
Where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
Transfer and storage of your information
Emails you send us will be stored within the European Economic Area on our third party email provider’s servers in the UK. Transfers of your information outside the European Economic Area.
Contact form
When you contact us using our contact form, we collect your contact details.
If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.
If you do not supply the optional information required by our contact form, we may not be able to contact you and deal with your request.
Legal basis for processing
Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s)
Responding to enquiries and messages we receive and keeping records of correspondence.
Legal basis for processing
Necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why it is necessary to perform a contract
Where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
When you contact us by phone
We collect your phone number and any information provided to us during your conversation with us.
We do not record phone calls.
Legal basis for processing
Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
Legitimate interest(s)
Responding to enquiries and messages we receive and keeping records of correspondence.
Legal basis for processing
Necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why it is necessary to perform a contract
Where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
Information we collect when you interact with our website
We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.
E-Newsletter
When you sign up for our e-newsletter or opt to receive news and offers from us by email, we collect contact details in order to complete this.
Legal basis for processing
Your consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent
You give your consent to us sending you our e-newsletter by signing up to receive it using the steps described above.
Transfer and storage of your information
We use a third party provider, the provider is MailerLite.
Registering on our website
When you register and create an account on our website, we collect the following information: name, address, phone number and any other information you provide to us when you complete the registration form.
If you do not provide the mandatory information required by the registration form, you will not be able to register or create an account on our website.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest
Registering and administering accounts on our website to [insert purpose e.g. to provide access to content] [and facilitate the running and operation of our business.
Information we collect when you place an order
We collect and use information from individuals who place an order on our website in accordance with this section and the section entitled Disclosure and additional uses of your information.
Information collected when you place an order
When you place an order for goods or services on our website, we collect your name, email address, billing address, shipping address, company name (if applicable) and phone number.
If you do not provide this information, you will not be able to purchase goods or services from us on our website or enter into a contract with us.
Legal basis for processing
Necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract
We need the mandatory information collected by our checkout form to establish who the contract is with and to contact you to fulfil our obligations under the contract, including sending you receipts and order confirmations.
Legal basis for processing
Compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation
We have a legal obligation to issue you with an invoice for the goods and services you purchase from us where you are VAT registered and we require the mandatory information collected by our checkout form for this purpose. We also have a legal obligation to keep accounting records, including records of transactions.
Processing your payment
After you place an order on our website you will need to make payment for the goods or services you have ordered. In order to process your payment we use a third party payment processor called Stripe.
Stripe collects, uses and processes your information, including payment information, in accordance with their privacy policies.
Marketing communications
When registering an account you will have the option of receiving marketing communications from us.
Our similar goods and services
You can opt-out from receiving marketing communications in relation to our goods and which are similar to those which you purchase from us, by opting out in your account area.
We will send you marketing communications in relation to similar goods and services if you do not opt out from receiving them.
Legal basis for processing
Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests
Direct marketing and advertising our products and services.
Our goods and services
You can opt in to receiving marketing communications from us in relation to our goods and services by selecting to opt in within your account area.
We will send you marketing communications in relation to our goods and services only if you opt-in to receive them.
Legal basis for processing
Consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent
You give your consent to us sending you information about our goods and services by signing up to receive such information in accordance with the steps described above.
Disclosure of your information to service providers
We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business and who process your information for us on our behalf, these include the following,
Email provider(s) and website hosting etc are all provided by Ionos. Their privacy policy is available here: https://www.ionos.co.uk/terms-gtc/privacy-policy/
Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us.
Legal basis for processing
Legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest relied on
Where we share your information with these third parties in a context other than where it is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently.
Legal basis for processing
Necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract
We may need to share information with our service providers to enable us to perform our obligations under that contract or to take the steps you have requested before we enter into a contract with you.
Disclosure of your information to other third parties
We disclose your information to other third parties in specific circumstances, as set out below.
Providing information to third parties such as Google Inc. Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/
Legal basis for processing
Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s)
Meeting our contractual obligations to Google under our Google Analytics Terms of Service (https://www.google.com/analytics/terms/us.html)
Transfer and storage of your information
Information collected by Google Analytics is stored outside the European Economic Area on Google’s servers in the United States of America.
For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled
Accountants
We share information with our accountants for tax purposes. For example, we share invoices we issue and receive with our accountants for the purpose of completing tax returns and our end of year accounts.
Legal basis for processing
Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest
Running and managing our business effectively.
Disclosure and use of your information for legal reasons
Indicating possible criminal acts or threats to public security to a competent authority
If we suspect that criminal or potential criminal conduct has occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that fraud or a cyber crime has been committed or if we receive threats or malicious communications towards us or third parties.
We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.
Legal basis for processing
Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests
Preventing crime or suspected criminal activity (such as fraud).
In connection with the enforcement or potential enforcement our legal rights
We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).
Legal basis for processing
Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest
Enforcing our legal rights and taking steps to enforce our legal rights.
In connection with a legal or potential legal dispute or proceedings
We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process
Legal basis for processing
Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s)
Resolving disputes and potential disputes.
For ongoing compliance with laws, regulations and other legal requirements
We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one.
Legal basis for processing
Compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation(s)
Legal obligations to disclose information which are part of the laws of England and Wales or if they have been integrated into the United Kingdom’s legal framework (for example in the form of an international agreement which the United Kingdom has signed).
Legal basis for processing
Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest
Where the legal obligations are part of the laws of another country and have not been integrated into the United Kingdom’s legal framework, we have a legitimate interest in complying with these obligations.
How long we retain your information
This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.
Server log information
We retain information on our server logs for at least 12 months.
Order information
When you place an order for goods and services, we retain that information for six years following the end of the financial year in which you placed your order, in accordance with our legal obligation to keep records for tax purposes.
E-Newsletter
We retain the information you used to sign up for our e-newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our e-newsletter service, whichever comes earlier.
Criteria for determining retention periods
In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:
How we secure your information
We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including, only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible.
Using secure servers to store your information
Verifying the identity of any individual who requests access to information prior to granting them access to information;
Using Secure Sockets Layer (SSL) software to encrypt any information you submit to us via any forms on our website and any payment transactions you make on or via our website.
Transmission of information to us by email
Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.
We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.
Google Analytics
Information collected by Google Analytics (your IP address and actions you take in relation to our website) is transferred outside the EEA and stored on Google’s servers. You can access Google’s privacy policy here: https://www.google.com/policies/privacy/
Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.]—
Safeguard(s) used: Google has self-certified its compliance with the EU-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm
Your rights in relation to your information
Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by contacting us to request access to your information and information related to our use and processing of your information,
To request the correction or deletion of your information.
To request that we restrict our use of your information.
To receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);
To object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and
To withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.
In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.
For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available here: https://ico.org.uk/global/contact-us/
Further information on your rights in relation to your personal data as an individual
The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s website:
https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/
You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here: http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf
Verifying your identity where you request access to your information
Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.
These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.
How we verify your identity
Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.
If it is not possible to identify you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.
We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.
Your right to object to the processing of your information for certain purposes
You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by contacting us.
To object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests, including ‘profiling’ (i.e. analysing or predicting your behaviour based on your information) based on any of these purposes; and
To object to us using or processing your information for direct marketing purposes including any profiling we engage in that is related to such direct marketing.
You may also exercise your right to object to us using or processing your information for direct marketing purposes by clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link. Updating your marketing preferences from your account area.
Sensitive Personal Information
Sensitive personal information is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.
We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.
If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.
Changes to our Privacy Policy
We update and amend our Privacy Policy from time to time.
Minor changes to our Privacy Policy
Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.
Major changes to our Privacy Policy.
When we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.
We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.
Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.
