Privacy Policy

 What is the purpose of this document?

The regulations with regards to personal data are being updated in the form of the General Data Protection Regulation (GDPR) which will apply from 2018.

u4coffee is committed to protecting the privacy and security of your personal information.

We are what is called a ‘controller’ of the personal information which we gather and use. This means we are responsible for deciding how we hold and use personal information about you. This policy explains to you what decisions we have taken in relation to that information.

Our contact details are as follows:

u4coffee, Unit 4, Highlands Road, Solihull, B90 4ND
u4coffee is a trading name of Cafe Azzurro Events Limited.

This privacy policy describes how we collect and use personal information about you during and after your business relationship with us, in accordance with the General Data Protection Regulation (GDPR). We encourage you to read this policy carefully, together with any other privacy policy we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information. It applies to all customers and suppliers.

We are not required to appoint a Data Protection Officer due to the nature of our core business activities, the small scale of personal data processing that we carry out and its secondary purposes, such as contact and payments. However, to broadly oversee compliance with regards to GDPR and to provide a single point of contact within the business for any queries a representative is available. If you have any questions about this privacy policy or how we handle your personal information, please contact Nicki Willetts MD at the business address and contact details above.

As a data controller, we are responsible for deciding how we hold and use personal information about you. This policy explains to you what decisions we have taken in relation to that information.

General Data protection principles

In collecting and processing your personal information, we will comply with the data protection law in force at the time. This requires that the personal information we hold about you must be:

  1. Used lawfully, fairly and in a transparent way.
  2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  3. Relevant to the purposes we have told you about and limited only to those purposes.
  4. Accurate and kept up to date.
  5. Kept only as long as necessary for the purposes we have told you about.
  6. Kept secure and confidential using appropriate technical and operational means.

The kind of information we hold about you

We will collect, store, and use a variety of categories of personal information about you. Those
categories are detailed in the Schedule to this policy on page 5.

How is your personal information collected?

We collect personal information about you, our customers and suppliers, directly from you when you speak to us on the telephone, email us, use our website or fill out a web form. We may sometimes collect additional information from third parties including credit reference agencies and/or other background credit agencies.

How we will use information about you

We will only use your personal information when the law allows us to and as detailed in the Schedule to this policy.

Situations in which we will use your personal information

There are a variety of situations in which we will use the information we collect about you and these are detailed in the Schedule to this policy.

Where we use your personal information to pursue the legitimate interests of the business, we will only do so provided your interests and fundamental rights do not override those interests.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to perform the business contract we have entered into with you (such as delivering products to you or paying you).

Change of purpose

We will only use your personal information 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 we need to use your personal information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Do we need your consent to use particularly sensitive information?

We do not need your consent if we use your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

Why might we share your personal information with third parties?

We may have to share your data with third parties, including third-party service providers. We require third parties to respect the security of your data and to treat it in accordance with the law.

We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

Any third parties with whom we might share your personal information and the basis on which we do so are detailed in the Schedule to this policy.

Data security

We have in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from the aforementioned business representative.

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

Data retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Your duty to inform us of changes

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

Your rights in connection with personal information

Under certain circumstances, the law grants you specific rights. These are summarised below. Please note that your rights may be limited and subject to restrictions in certain situations:

Request access to your personal information (commonly known as a ‘data subject access request’). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the aforementioned business representative.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is unfounded or excessive. Alternatively, we may refuse to comply with the request in such 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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In any circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the aforementioned business representative. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Complaints to the ICO

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.

Changes to this privacy policy

We reserve the right to update this privacy policy at any time, and we will provide you with a new privacy policy when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

DATED: 25th May 2018

THE SCHEDULE

ABOUT THE INFORMATION WE COLLECT AND HOLD

The information we collect How we collect the information Why we collect the information How we use and may share the information
Your name, contact details (i.e. business/home address, business/home and business/personal mobile phone numbers, business/personal email address). From you. To enter into/perform the business relationship/contract.Legitimate interest: to maintain business records and good business practice. To enter into/perform the business relationship/ contract.To provide you with information that we believe you would like to be made aware of e.g. system changes, new or improved products.
Details of business/personal bank/building society. From you. To perform the business contract including receipt of payments or payments for goods or services.Legitimate interest: to maintain business records and to comply with legal, regulatory and corporate governance obligations and good business practice. To ensure you receive what has been purchased or the correct payment for goods or services.Information shared with our accountants (Angel Accounting) and with HM Revenue & Customs (HMRC).
Details of sales/purchase history. From you. To comply with our legal obligations.Legitimate interest: to maintain business records and to comply with legal, regulatory and corporate governance obligations and good business practice. To comply with legal/regulatory obligations.

Information shared with our accountants (Angel Accounting) and with HM Revenue & Customs (HMRC).

U4coffee

Privacy Policy – Customers and Suppliers

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