SOZAI LIMITED, trading as Sozai Cooking School, 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 visits this website,www.sozai.co.uk (“Our Site”) 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.
1. 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 Site; “Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and “Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
2. Information About Us
2.1 www.sozai.co.uk is a Site owned and operated by SOZAI LIMITED, a company registered in England under company number 08229219 and whose registered address is Unit 3, Hyde Estate Road, London NW9 6JX. 2.2 You can contact us by: · writing to us at the above address · emailing us at email@example.com; · Calling us on 020 7458 4567
3. What Does This Policy Cover?
4. 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.
5. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
h) 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. i) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 2.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you 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 use of your 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 2.
6. What Data Do You Collect and How?
· Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender. · Contact Data includes billing address, home and/or contact address, email address and telephone numbers. · Financial Data includes bank account and payment card details. · Transaction Data includes details about payments to and from you and other details of orders submitted and accepted through our Site. · Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. · Profile Data includes your username and password, profiles, your interests, preferences, feedback and survey responses. · Usage Data includes information about how you use our website and services. · Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
7. How Do You Use My Personal Data? Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following describes how we may use your personal data, and our lawful bases for doing so.
Purpose/Activity To process a registration request and orders, take payments including managing payments, fees and charges, to collect payments from diners and make payments to chefs. Type of data Identity, Contact, Financial, Transaction, Profile, Marketing and Communications Lawful basis for processing including basis of legitimate interest Performance of a contract with you Necessary for our legitimate interests to take and make payments
Purpose/Activity To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) Type of data Identity, Contact, Profile, Marketing and Communications Lawful basis for processing including basis of legitimate interest Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how users use our Site)
Purpose/Activity To use data analytics to improve our website, services, marketing, customer relationships and experiences Type of data identity, Contact, Technical Lawful basis for processing including basis of legitimate interest Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation
Purpose/Activity To make suggestions and recommendations to you about new classes and offers or services that may be of interest to you Type of data Contract, Technical Usage Lawful basis for processing including basis of legitimate interest Necessary for our legitimate interests (to define types of chefs for our diner’s needs and to inform all users of our services, to keep our Site updated and relevant, to develop our business and to inform our marketing strategy)
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with information, news, and offers on our services of those of the chefs on the Site, and diner requests. You 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.
We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time. Third Parties whose content appears on Our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
We will only use your 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 personal data for that purpose. If we do use your 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 2.
If we need to use your 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.
8. How Long Will You Keep My Personal Data?
We will only retain your personal data 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.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
9. How and Where Do You Store or Transfer My Personal Data?
Personal information we collect may be stored and processed in the United Kingdom or in any other country where we or our affiliates, subsidiaries or service providers maintain facilities. We take steps designed to ensure that the data we collect under this Statement is processed according to the provisions of this Statement and applicable law wherever the data is located.
When we transfer personal information from the European Economic Area and Switzerland to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection, we use a variety of legal mechanisms, including contracts, in an effort to help ensure your rights and protections.
For EU Users - Your European Privacy Rights We adhere to applicable data protection laws in the European Economic Area, which, if applicable to you, includes the following rights:
If we are processing personal information based on your consent, you have a right to withdraw consent at any time for future processing; You have a right to request access to, rectification, or erasure of your personal information, or to transfer or receive a copy of your personal information in a usable format; You have a right to object to the processing of your personal information under certain circumstances; and You have a right to lodge a complaint with a data protection authority.
For EU Users - Privacy Shield
Our participation in Privacy Shield applies to personal data that is received from the European Economic Area and Switzerland. We will comply with the Privacy Shield Principles in respect of all such personal data.
If we transfer your personal information to a third party agent or service provider for processing, we remain potentially liable under the Privacy Shield Principles if our third party agent or service provider processes your personal information in a manner inconsistent with the Privacy Shield Principles and this causes you harm, unless we are able to show that we are not responsible for the event leading to that harm.
10. Do You Share My Personal Data?
We may share your personal information with:
· Cooking instructors and their assistants in respect of the classes/courses/events you have booked. · Our third party payment processing agent, Stripe. As we use a third party payment processing agent to collect and make payments, their terms and conditions will apply. · Service providers acting as processors who provide IT and system administration services. · Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide banking, legal, insurance and accounting services. · Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. · In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.
11. How Can I Control My Personal Data?
In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, 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.
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.
12. Can I Withhold Information?
You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
13. 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”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 2.
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 28 days. 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.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We use the following cookies:
• Strictly necessary cookies. These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas of our Site, use a shopping cart or make use of e-billing services. • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily. • Functionality cookies. These are used to recognise you when you return to our Site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region). • Targeting cookies. These cookies record your visit to our Site, the pages you have visited and the links you have followed. We will use this information to make our Site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
15. Changes to this Policy
We may change this Privacy Notice 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.
Contact Sozai Cooking School, 5 Middlesex Street, London E1 7AA firstname.lastname@example.org 020 7458 4567