Introduction

Here at Kitchies we respect your privacy and we are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or purchase our goods or services and tells you about your privacy rights and how the law protects you. 

This privacy policy is provided in a layered format so you can read through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

IMPORTANT INFORMATION AND WHO WE ARETHE DATA WE COLLECT ABOUT YOUHOW IS YOUR PERSONAL DATA COLLECTED?HOW WE USE YOUR PERSONAL DATADISCLOSURES OF YOUR PERSONAL DATAINTERNATIONAL TRANSFERSDATA SECURITYDATA RETENTIONYOUR LEGAL RIGHTS GLOSSARY 
1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Kitchies Ltd collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up for an account or purchase a product or service from us. 

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them. 

Controller

Kitchies Ltd, a company incorporated in England and Wales with company number 10439753 and its registered address at 20-22 Wenlock Road, London, N1 7GU is the controller and responsible for your personal data (referred to as "Kitchies", "we", "us" or "our" in this privacy policy).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact our data privacy manager using the details set out below. 

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: Kitchies Ltd

Email address: contact@lualu.co.uk

Postal address: 27A Diana Street, Newcastle Upon Tyne, NE4 6BQ

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. 

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 21 September 2022. Historic versions can be obtained by contacting us.

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

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

Personal data, or personal information, 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 as follows:

Identity Data includes first name, last name, username or similar identifier, title, date of birth and social media accounts.

Contact Data includes billing address, delivery address, email address and telephone numbers.

Financial Data includes payment card details, PayPal details and gift card or referral credit.

Transaction Data includes details about payments to and from you and other details of products, any subscriptions you have ordered and services you have purchased from us.

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, advertising channels used to arrive at our website, referral pages, operating system and platform, and other technology on the devices you use to access this website. 

Profile Data includes your username and password, referrals you have made, purchases or orders made by you, your food preferences, feedback and survey responses.  

Usage Data includes information about how you use our website, products and services. 

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share 

Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

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.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, if you do not provide us with a correct address we cannot send orders to you). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time. 

3. How is your personal data collected?

We use different methods to collect data from and about you, including through:

Direct interactions.You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us or contacting us by post, phone, email or otherwise. This includes personal data you provide when you:order our products or services;create an account on our website;subscribe to make regular orders; refer a friend;request for marketing to be sent to you; orenter a competition, promotion or survey. 

Automated technologies or interactions.As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see ourcookie policy for further details.

Third parties or publicly available sources.We may receive personal data about you from various third parties and public sources as set out below: Technical Data from the following parties:analytics providers such as Google Analytics (based both outside and inside of the EU and the UK) and Klaviyo (based outside the EU and the UK); andadvertising networks such as Google Ads (based both inside and outside of the EU and the UK), MentionMe (based both inside and outside of the EU and the UK) and Groupon (based both inside and outside of the EU and the UK).Contact, Financial and Transaction Data from providers of technical, payment and delivery services, such as the Royal Mail (based inside the UK) or Stripe (based both outside and inside of the EU and the UK).Identity and Contact Data from publicly available sources such as Twitter, Facebook, Instagram, TikTok and similar social media platforms.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.Where we need to comply with a legal obligation.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us or by using the “unsubscribe” option provided in our marketing emails.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Marketing 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. 

Promotional offers from us 

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). 

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Third-party marketing 

We will always get your express opt-in consent before we share your personal data with any third party for marketing purposes. 

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by either (i) logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences; (ii) by following the opt-out links on any marketing message sent to you; or (iii) by contacting us at any time. 

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

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.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table [Purposes for which we will use your personal data] above.

External Third Parties as set out in the [Glossary].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 policy. 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We do not transfer your personal data outside the European Economic Area (EEA) or the UK.

Many of our external third parties are based outside the EEA and/or the UK so their processing of your personal data may involve a transfer of data outside the EEA and/or the UK. Whenever they do so, we always ensure that a similar degree of protection is afforded to your data by ensuring at least one of the following safeguards is implemented by that third party: 

Transfers of personal data may be made to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission and/or any other relevant authority. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.Specific contracts approved by the European Commission and/or any other relevant authority which give personal data the same protection it has in Europe/the UK are in place. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.  That third party has binding corporate rules in place in compliance with the relevant data protection laws.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA and/or the UK.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We use strong user authenticated access to our systems and we are constantly improving and upgrading our systems security. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 

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

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see [your legal rights] below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. 

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights: 

[Request access to your personal data].[Request correction of your personal data].[Request erasure of your personal data].[Object to processing of your personal data].[Request restriction of processing your personal data].[Request transfer of your personal data].[Right to withdraw consent].

If you wish to exercise any of the rights set out above, please contact our data privacy manager [link to contact details]. 

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these 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 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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

External Third Parties

Service providers acting as processors, including:Shopify, who provide order processing and system administration services based in the USA and Canada;MentionMe, who provides a customer referral programme hosted in France, Ireland and the UK;Storilabs ERP, an enterprise planning system hosted in the UK;Business Intelligence, a data warehouse provider hosted in the UK;Klaviyo, a mailing list management and analysis service hosted both outside and inside of the EU and the UK;Google Drive, a cloud-based file storage host and synchronised service provider hosted in the UK and worldwide;OnFleet, a logistics management software provider whose services are hosted in the US, the EEA and the worldwide; Digital Ocean, a cloud computing services provider hosted in the UK;Royal Mail, a logistics provider based in the UK;Yodel, a logistics provider based in the UK; DHL, a logistics provider based in the UK; Various software and website development agencies based in the UK, EU & Canada;Google, who provide analytics and advertising services hosted both outside and inside of the EU and the UK;Facebook, who provide analytics and advertising services hosted both outside and inside of the EU and the UK;Twitter, who provide analytics and advertising services hosted both outside and inside of the EU and the UK; andFifty Digital, who provide advertising services hosted both outside and inside of the EU and the UK.Twilio, who provide communication services hosted both outside and inside of the EU and the UK.Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

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

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.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data 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. 

Object to processing of your personal data 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. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: 

If you want us to establish the data's accuracy.Where our use of the data is unlawful but you do not want us to erase it.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. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 

Request the transfer of your personal data to you or to a third party. 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. 

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.