Privacy Policy

Background‍
City Brands Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who   uses or whose data is stored on our platform (“Our Platform”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
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Please read this Privacy & Cookies Policy carefully and ensure that you understand it. Your acceptance of the Cookies part of this Privacy & Cookies Policy will occur when you tick the consent box on Our Platform and your acceptance of the privacy part of this Privacy & Cookies Policy is deemed to occur upon your first use of Our Platform AND/OR You will be required to provide express consent by reading and accepting this Privacy & Cookies Policy when signing up for an Account to use Our Platform. If you do not accept and agree with this Privacy & Cookies Policy, you must stop using Our Platform immediately. If you are not a City Brands Ltd customer but a customer of a Brand (“Brand Customer”)  reading this Privacy & Cookies Policy because you have been made aware your personal data may be collected by or stored with us, and you are concerned or have questions around such use of your personal data, please contact the Account holder who is using Our Platform to process your personal data.

Definitions and Interpretation In this Policy the following terms shall have the following meanings:  
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“Account” means an account required to access and/or use certain areas and features of Our Platform;

"Brand" means a food or beverage brand that is either owned by us or a third party brand contracting to use Our Platform;

“Cookie”means a small text file placed on your computer or device  when you visit certain parts  when you use certain features of Our Platform. Details of the Cookies used  are set out in Part 14 below;

“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;
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Information
Our Platform is owned and operated by City Brands Ltd a Limited company registered in England and Wales under company number 11913309.Registered address: 21b, Primrose Road, London, E10 5EE

Data Protection Officer & Representative
Harvey Hodd (Email address: hello@citybrands.info)

What Does This Policy Cover?
This Privacy & Cookies Policy applies to your use of  Our Platform and how we process Brand Customer personal data. Please note that we have no control over how your data is collected, stored, or used by other Brands and we advise you to check the privacy policies of any such Brands before providing any data to them.
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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.
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What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:The right to be informed about our collection and use of your Brand Customers’ personal data.

This Privacy & Cookies Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15. The ICO has more guidance on their website, here.

The right to access the personal data we hold about your Brand Customers. Part 13 will tell you how to do this. The ICO has more guidance on their website, here.

The right to have your Brand Customers’ personal data rectified if any such personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more. The ICO has more guidance on their website, here.

The right to ask us to delete or otherwise dispose of any of your Brand Customers’ personal data that we hold. Please contact us using the details in Part 15 to find out more. The ICO has more guidance on their website, here.

The right to restrict (i.e. prevent) the processing of your Brand Customers’ personal data. Please contact us using the details in Part 15 to find out more. The ICO has more guidance on their website, here.

The right to object to us using your Brand Customers’ personal data for a particular purpose or purposes.  Please contact us using the details in Part 15 to find out more. The ICO has more guidance on their website, here.

The right to withdraw consent.
This means that, if we are relying on your consent as the legal basis for using your Brand Customers’ personal data, you are free to withdraw that consent at any time.  Please contact us using the details in Part 15 to find out more.The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.  Please contact us using the details in Part 15 to find out more.Rights relating to automated decision-making and profiling. We do not use your Brand Customers’ personal data in this way.It is important that your Brand Customers’ personal data is kept accurate and up-to-date. If any of the personal data we hold about you or your Brand Customers changes, please keep us informed as long as we 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 use of your Brand Customers’ personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves however, so please contact us first, using the details in Part 15.

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What Data Do You Collect and How?
Depending upon your use of Our Platform, we 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. Please also see Part 14 for more information about our use of Cookies and similar technologies. We do not collect any ‘special category’ or ‘sensitive’ personal data or personal data relating to children but please refer to Part 16 on this.
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How We Collect the Data
Lawful Basis Brand Customer Identity Information including first name, last name, title,  gender Via Brands, Our Platform via SMS text message, any installed plugins, online ordering through Our Platform chatbots over the telephone or via email or social media interaction, vending machines, pop up stores and other general marketing and events. Sometimes data may be collected automatically through these mediums:
     • Consent
     • Contract
     • Legitimate Interest
     • Legal Obligation

Brand Customer Contact information including address, email address, telephone numbers Via Brands or Our Platform via SMS text message, any installed plugins, online ordering through Our Platform chatbots over the telephone or via email or social media interaction, vending machines, pop up stores and other general marketing and events. Sometimes data may be collected automatically through these mediums. ConsentContractLegal Obligation Legitimate Interest Brand Customer Payment information including card details, bank account numbers, CVV codes Via Brands or Our Platform via SMS text message, any installed plugins, online ordering through Our Platform chatbots over the telephone or via email or social media interaction, vending machines, pop up stores and other general marketing and events. Sometimes data may be collected automatically through these mediums. Contract Legal ObligationLegitimate Interest Brand Customer Profile information including login details, purchase history Via Brands and Our Platform and related servers. Sometimes data may be collected automatically through these mediums.ContractLegitimate InterestTechnical information including location tracking apps installed on mobile devices, IP address, browser type and version, country, operating system applicable to Brand Customers Via Our Platform and related servers. Sometimes data may be collected automatically through these mediums for example through push notifications.Legal ObligationLegitimate InterestData from Brands Sometimes data may be collected automatically through these mediums and passed through Our Platform for example IP addresses. Contract Legitimate Interest  

How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data which comprises consent, contract, legal obligation and legitimate interests. More details on each lawful basis and examples of how we use your or your Brand Customers’ personal data under each basis are as follows:
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Consent
Where you have expressly provided consent to receive communications from us such as newsletters, emails, marketing materials, news and events. Where your Brand Customers have expressly provided consent to receive communications via SMS text message.
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Contract
Your Brand Customers’ personal data is necessary for us to administer the pre-purchase, purchase, order fulfilment and dispatch and contractual relationship with each Brand so that we may facilitate your Brand Customers’ purchases or payments, store and record your Brand Customers’ purchases and previous orders and keeping you updated with any changes in our terms and policies as well as offering you additional products, services and benefits as a valued customer of us.

Legitimate Interest
Where you have provided your email address or other personal data to us, either online or offline, we may add you to our database or the appropriate Brand’s database on Our Platform for emails to contact you about new products, news and events, exclusive sales and marketing events. Where Brand Customers have provided their email address or mobile telephone number or other personal data to you via Our Platform, we may add such personal data to the appropriate Brand’s database on Our Platform for your Brand to manage direct marketing to their Brand Customers about new products, news and events, exclusive sales and marketing events. Certain personal data is also needed for legitimate purposes to prevent fraud, security breaches, legal violations, for us or a Brand to help recommend products to Brand Customers and to understand more about Brand Customers and targeted customer base as well as to help Our Platform to switch to the correct currency, language and delivery options if applicable. We may also use the personal data collected under this lawful basis to help us analyse and administer, improve and update Our Platform for better experience, better products and service we offer.
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Legal Obligation
Certain personal data you provide us is necessary for us to fulfil our legal obligations as a business for example, verifying your age and appropriate use of  Our Platform, preventing fraud, security breaches and complying with our tax and accounting obligations where needed as well as complying with our obligations and responsibilities under any contractual relationship we may have with a Brand in respect of rights to use Our Platform.

You and your Brand Customers will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our 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. See Part 11 for more details.We will only use your or your Brand Customers’ personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your or your Brand Customers’ personal data for that purpose. If we do use your or your Brand Customers’ personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.If we need to use your or your Brand Customers’ personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.In some circumstances, where permitted or required by law, we 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.
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How Long Will You Keep My Personal Data?
We will not keep your or your Brand Customers’ personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Even if we delete your or your Brand Customers’ personal data, it may still exist on backup or archival media for legal, tax or regulatory purposes. If a Brand ceases to use Our Platform for any reason, Brand Customers’ personal data may exist on the Brand’s systems. Brand Customers should always refer to the privacy policy for each Brand from whom they may purchase products.

How and Where Do You Store or Transfer My Personal Data?
We will store or transfer some of your or your Brand Customers’ personal data within the United Kingdom and 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.
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We may store or transfer some or all of your or your Brand Customers’ personal data in countries that are not part of the United Kingdom or the 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 will take additional steps in order to ensure that your or your Brand Customers’ 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 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 (https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu_en).Please contact us using the details below in Part 15 for further information about the particular data protection mechanisms used by us when transferring your or your Brand Customers’ personal data to a third country. The security of your and your Brand Customers’ personal data is essential to us and to protect such data, we take a number of important technical and organisational measures, including the following:limiting access to your or your Brand Customers’ personal data to those employees, agents, contractors, and other third parties  including Brands with a legitimate need to know and ensuring that they are subject to duties of confidentiality and aware of any obligations relating to the use of your personal data by them; and 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 legally required to do so.
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Do You Share My Personal Data?
Subject to part 9, We will not share any of your or your Brand Customers’ personal data with any third parties for any purposes, subject to the following exception[s].If we sell, transfer, or merge parts of our business or assets, your or your Brand Customers’ personal data may be transferred to a third party. We may be legally required to share certain personal data, which might include yours or your Brand Customers’, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority. We may sometimes contract with the following third parties to supply certain services.
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Recipient - Activity Carried Out - Sector - Location

Monthly Subscriptions
By purchasing a Monthly Subscription, you agree to an initial and recurring monthly subscription fee at the then-current Monthly Subscription rate, and you accept the responsibility for all recurring charges until you cancel your subscription. You may cancel your Monthly Subscription at any time, subject to the terms and conditions of our cancellation policy.

Annual Subscriptions
By purchasing a Monthly Subscription, you agree to a payment for one full year of service. After one year and annually thereafter, you will be billed a recurring Annual Subscription renewal fee at the then-current Annual subscription rate. We will notify you before the renewal fee is billed. You may cancel your Annual Subscription at any time, subject to the terms and conditions of our cancellation policy.

Cancellation Policy
You may cancel your Monthly Subscription at any time. You will have usage of the Blueprint solution until your next due billing period at which time your usage will stop. Monthly Subscriptions are non-refundable once payment has been made for the monthly usage until the next due billing period.

You may cancel your Annual Subscription at any time. You will have usage of the Blueprint solution until your next due billing period at which time your usage will stop. Annual Subscriptions are non-refundable once initial payment has been made for the yearly usage until the next due billing period.

Payment Processing
[platform provider] (Data Processor) Payment processing, order processing Customer Relationship Management e-commerce UK [Stripe or other processor] on Our Platform Payment processing Gateway e-commerce UK Logistics providers e.g. warehousing and shipping partnersOrder fulfilment and dispatch services e-commerce UK Google Analytics Measure and track user experience on Our Platform e-commerce UK Private Chat Plugin: Allow Brand Customers to liaise with Brands prior or after any purchase is made After sales service UK Brands Sharing Brand Customer data, personal data of customers, sales data as part of services offered through Our PlatformLicensing of Our Platform UK
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If any of your or your Brand Customer personal data is shared with a third party, as described above, we will take steps to ensure that such personal data is handled safely, securely, and in accordance with and as described above in Part 9.
How Can I Control My Personal Data? In addition to your rights under the Data Protection Legislation, set out in Part 5, when you or your Brand Customers submit personal data via Our Platform, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details and by managing your Account). We do not undertake any direct marketing with your Brand Customers at all though Our Platform may be used by Brands to market to Brand Customers via SMS text message. If you are based in the United Kingdom, 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.
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Can I Withhold Information?
You may access certain areas of Our Platform without providing any personal data at all. However, to use all features and functions available on Our Platform you may be required to submit or allow for the collection of certain data.
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How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us 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”. Brand Customers wishing to know what personal data we store via Our Platform will need to initiate a subject access request directly with you as the Brand and you will then need to notify us as set out below and we will work with you to provide a complete response.All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. 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 administrative costs in responding.We will respond to your subject access request within 14 calendar days and, in any case, not more than one month of receiving it. Normally, we 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 receive your request. You will be kept fully informed of our progress.
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How Do You Use Cookies?
Our Platform may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We may use Cookies to facilitate and improve your experience of Our Platform and to provide and improve our products and services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times. By using Our Platform, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies may be used on Our Platform for analytics and SEO such as Google Analytics and Google Tag Manager. These Cookies are not integral to the functioning of Our Platform and your use and experience of Our Platform will not be impaired by refusing consent to them.All Cookies used by and on Our Platform are used in accordance with current Cookie Law.Before non-essential Cookies are placed on your computer or device, you will be shown a pop up screen requesting your consent to set those Cookies. By giving your consent to the placing of these Cookies you are enabling us 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 Platform 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 Platform may depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. 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 Platform may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
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Our Platform may use analytics services from time to time. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Platform is used. This, in turn, enables us to improve Our Platform and the products and services offered through it. You may contact us for more details on strictly necessary and third party Cookies we use.
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In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Platform more quickly and efficiently including, but not limited to, login and personalisation settings.It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
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General
You may not transfer any of your rights under this Privacy & Cookies Policy to any other person. Subject to Our Platform terms and conditions, anyone under the age of 18 should not use Our Platform but in the event someone under the age of 18 uses Our Platform and accepts this Privacy & Cookies Policy without parental responsibility consent or on another unauthorised basis, We shall not be liable for any breach of the Data Protection Legislation relating to the personal data We collect as a result of such use. We may transfer our rights under this Privacy & Cookies Policy where we reasonably believe your or your Brand Customers’ rights will not be affected.If any court or competent authority finds that any provision of this Privacy & Cookies Policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Privacy & Cookies Policy will not be affected.Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy. This Privacy & Cookies Policy will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.
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Changes to this Privacy & Cookies Policy
We may change this Privacy & Cookies Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. Any changes will be immediately posted on Our Platform or emailed to you and you will be deemed to have accepted the terms of the Privacy & Cookies Policy on your first use of Our Platform following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy & Cookies Policy was last updated on 12/01/21.
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