Privacy Policy

The Cookit Club Ltd

Company Number 15939111

Haywain, Kingswood Road, Bromley, BR2 0HQ, United Kingdom

Website Privacy Policy

1 INTRODUCTION

1.1 Important information and who we are

Welcome to The Cookit Club Ltd’s Privacy and Data Protection Policy (“Privacy Policy”).

At The Cookit Club Ltd (“we”, “us”, or “our”) we are committed to protecting and respecting

your privacy and Personal Data in compliance with the United Kingdom General Data

Protection Regulation (“GDPR”), the Data Protection Act 2018 and all other mandatory laws

and regulations of the United Kingdom.

This Privacy Policy explains how we collect, process and keep your data safe. The Privacy

Policy will tell you about your privacy rights, how the law protects you, and inform our

employees and staff members of all their obligations and protocols when processing data.

The individuals from which we may gather and use data can include any people that the

organisation has a relationship with or may need to contact.

This Privacy Policy applies to all our employees and staff members and all Personal Data

processed at any time by us.

1.2 Your Data Controller

The Cookit Club Ltd is your Data Controller and responsible for your Personal Data. We are

not obliged by the GDPR to appoint a data protection officer and have not voluntarily

appointed one at this time. Therefore, any inquiries about your data should either be sent

to us by email or by post to Haywain, Kingswood Road, Bromley, BR2 0HQ, United

Kingdom.

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.

1.3 Processing data on behalf of a Controller and processors’ responsibility to you

In discharging our responsibilities as a Data Controller we have employees who will deal

with your data on our behalf (known as “Processors”). The responsibilities below may be

assigned to an individual or may be taken to apply to the organisation as a whole. The

Data Controller and our Processors have the following responsibilities:

• Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR (see 2.2 below for more information);

• Ensure that Processors authorised to process Personal Data have committed
• themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;

• Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;

• Obtain the prior specific or general authorisation of the Controller before engaging another Processor;

• Assist the Controller in the fulfilment of the Controller's obligation to respond to requests for exercising the data subject's rights;

• Make available to the Controller all information necessary to demonstrate  compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller;

• Maintain a record of all categories of processing activities carried out on behalf of a Controller;

• Cooperate, on request, with the supervisory authority in the performance of its tasks;

• Ensure that any person acting under the authority of the Processor who has access
• to Personal Data does not process Personal Data except on instructions from the Controller; and

• Notify the Controller without undue delay after becoming aware of a Personal Data Breach.

2 LEGAL BASIS FOR DATA COLLECTION

2.1 Types of data / Privacy policy scope

“Personal Data” 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 below. Not all of the following types of data will necessarily be

collected from you but this is the full scope of data that we collect and when we collect it

from you:

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.

2.2 The Legal Basis for Collecting That Data

There are a number of justifiable reasons under the GDPR that allow collection and

processing of Personal Data. The main avenues we rely on are:

• “Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.
• “Contractual Obligations”: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service. 
• “Legal Compliance”: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
• “Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests - this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards.

3 HOW WE USE YOUR PERSONAL DATA

3.1 Our data uses

We will only use your Personal Data when the law allows us to.

3.2 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.

4 YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US

4.1 Your legal rights

Under certain circumstances, you have the following rights under data protection laws in

relation to your personal data:

Right to be informed. You have a right to be informed about our purposes for

processing your personal data, how long we store it for, and who it will be shared

with. We have provided this information to you in this policy.

• Right of access. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it (also known as a "data subject access request"). See section 4.3 below for more details on how you can make a data subject access request.

• Right to rectification. You have a right to request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Right to erasure. You have the right to ask us to delete or remove personal data where there is no good reason for us continuing to process it, where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request

• Right to object. You can object to the processing of personal data we hold about you. This effectively allows you to stop or prevent us from processing your personal data. Note that this is not an absolute right and it only applies in certain circumstances, for example:
  • (i) Where we are processing your personal data for direct marketing purposes.
  • (ii) 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 as you feel it impacts on your fundamental rights and freedoms.
  • (iii) In some cases, we may continue processing your data if we can demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Right to restrict processing. You have the right to request the restriction or suppression of their personal data. Note that this is not an absolute right and it only applies in certain circumstances:
  • (i) If you want us to establish the data's accuracy.
  • (ii) Where our use of the data is unlawful but you do not want us to erase it.
  • (iii) Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • (iv) You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Right to data portability. You have the right to request the transfer of your personal data to you or to a third party. If you make such a request, we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. 

If you wish to make a request under any of these rights, please contact us.

4.2 How The Cookit Club Ltd protects customers' Personal Data

We are concerned with keeping your data secure and protecting it from inappropriate

disclosure. Any Personal Data collected by us is only accessible by a limited number of

employees who have special access rights to such systems and are bound by obligations

of confidentiality. If and when we use subcontractors to store your data, we will not

relinquish control of your Personal Data or expose it to security risks that would not have

arisen had the data remained in our possession. However, unfortunately no transmission

of data over the internet is guaranteed to be completely secure. It may be possible for

third parties not under the control of The Cookit Club Ltd to intercept or access

transmissions or private communications unlawfully. While we strive to protect your

Personal Data, we cannot ensure or warrant the security of any Personal Data you

transmit to us. Any such transmission is done at your own risk. If you believe that your

interaction with us is no longer secure, please contact us.

4.3 How to request your data and the process for obtaining it

You will not have to pay a fee to access your Personal Data (or to exercise any of the other

rights). However, if your request is clearly unfounded, we could refuse to comply with your

request.

We may need to request specific information from you to help us confirm your identity

and ensure you have the 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.

5 YOUR DATA AND THIRD PARTIES

5.1 Sharing your data with third parties

We may also share Personal Data with interested parties in the event that The Cookit Club

Ltd anticipates a change in control or the acquisition of all or part of our business or assets

or with interested parties in connection with the licensing of our technology.

If The Cookit Club Ltd is sold or makes a sale or transfer, we may, in our sole discretion,

transfer, sell or assign your Personal Data to a third party as part of or in connection with

that transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern

the further use of your Personal Data. In all other situations your data will still remain

protected in accordance with this Privacy Policy (as amended from time to time).

We may share your Personal Data at any time if required for legal reasons or in order to

enforce our terms or this Privacy Policy.

6 HOW LONG WE RETAIN YOUR DATA

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes

we collected it for. We may retain your Personal Data for a longer period than usual in the event

of a complaint or if we reasonably believe there is a prospect of litigation in respect to our

relationship with you.

7 INTERNATIONAL TRANSFER OF DATA

Your information may be stored and processed in the US or other countries or jurisdictions

outside the US where The Cookit Club Ltd has facilities. By using The Cookit Club Ltd, you are

permitting and consenting to the transfer of information, including Personal Data, outside of the

US.

8 NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY

We keep our Privacy Policy under review and will place any updates here.

By using The Cookit Club Ltd, you consent to the collection and use of data by us as set out in this

Privacy Policy. Continued access or use of The Cookit Club Ltd will constitute your express

acceptance of any modifications to this Privacy Policy.

9 INTERPRETATION

All uses of the word "including" mean "including but not limited to" and the enumerated

examples are not intended to in any way limit the term which they serve to illustrate. Any email

addresses set out in this policy may be used solely for the purpose for which they are stated to

be provided, and any unrelated correspondence will be ignored. Unless otherwise required by

law, we reserve the right to not respond to emails, even if they relate to a legitimate subject

matter for which we have provided an email address. You are more likely to get a reply if your

request or question is polite, reasonable and there is no relatively obvious other way to deal with or answer your concern or question (e.g. FAQs, other areas of our website, etc.).

Our staff are not authorised to contract on behalf of The Cookit Club Ltd, waive rights or make

representations (whether contractual or otherwise). If anything contained in an email from a The

Cookit Club Ltd address contradicts anything in this policy, our terms or any official public

announcement on our website, or is inconsistent with or amounts to a waiver of any The Cookit

Club Ltd rights, the email content will be read down to grant precedence to the latter. The only

exception to this is genuine correspondence expressed to be from the The Cookit Club Ltd legal department.