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. 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: “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; 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: firstname.lastname@example.org)
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. 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. 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.
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: 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. 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. 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.
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. 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. 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. 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.