Privacy Policy

Last Updated: 12/10/23

Introduction

Mascarpony (also referred to as “we”, “us” or “our” in this Privacy Notice) are Artisan Cheese Specialists, operating from mobile premises in Surrey and Hampshire.

This Privacy Policy sets out how we look after your personal data when you visit our website and/or use our iOS or Android app, (together referred to as the “website” or “site”) and inform you of your privacy rights and how the law protects you.

This Privacy Notice should be read alongside our Website Terms of Use and Cookie Policy.

1. Important Information and Who We Are

Mascarpony Limited is incorporated and registered in England and Wales with company number 14196981 whose registered office is at Brambles, Hazeldene Road, Liphook, Hampshire, GU30 7PH.

Mascarpony Limited is the data controller responsible for the personal data we collect about you. If you have any questions about this Privacy Notice, please contact us at hello@mascarpony.co.uk.

This privacy notice is not contractual. We keep this privacy Notice under regular review and and we may update or amend it any time. This version was last updated in July 2023.

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.

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 notice of every website you visit.

2. The Personal 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 and Contact Data includes your first name and last name, billing address, delivery address, email address, telephone, mobile number and social media account details.
Financial Data means the payment method and card association used to process your payments for your orders. We do not store or process your card details ourselves, they are processed and automatically stored via one of our contracted third party service providers.
Photographs or videos – for some activities we may use photographs or videos of our customers who are involved in Mascarpony events or who provide testimonials for our website.
Technical Data means details about the device(s) you use to access our website including your internet protocol (IP) address, browser type and version, location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Usage Data includes information about how you use our website, products and services. This includes your browsing patterns and information such as how long you might spend on one of our webpages and what you look at and for on our website, the page that referred you to our site and the click stream during your visit to our website, page response times and page interaction information (clicks you make on a page).
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We also collect, use and share aggregated and/or anonymised data (“Aggregated Data”) such as statistical or demographic data for analytical purposes. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 Notice.

3. How We Collect Your Personal Data

We may collect your personal data directly. This could happen where you or your organisation is our customer or a prospective customer or supplier or prospective supplier to us, you communicate with us, you visit us or our website or attend our events.

We may also collect your personal data indirectly. This could happen where your personal data has been provided by:

Public records such as Electoral Register
Someone who has referred or recommended us to you
Someone who is authorised on your behalf such as Power of Attorney

4. How We Will 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 to provide you with goods or services
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests
Where you have provided your consent
Where we need to comply with a legal obligation

We have set out below, in a table format, a summary of the purposes for which we process your personal data (and which types) and the legal basis we rely on to carry out that processing lawfully.

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.

5. Disclosures of Your Personal Data

We may share your personal data with the following categories of recipients:

our professional advisers such as lawyers, accountants, consultants and marketing specialists
professional indemnity or other relevant insurers
organisations to whom we outsource certain services including office management systems, data hosting, website management, email marketing, confidential waste disposal, IT systems or software providers and document and information storage providers
service providers to assist us with client insight analytics, such as Google Analytics
or postal marketing campaigns (where carried out)
prospective buyers if we propose to sell all or any of our business and assets

We will share your personal data with such recipients only as necessary for the purposes set out in Section 4 and then only to the extent reasonably necessary for the purpose for which we are engaging, communicating or dealing with them.

Where organisations in any of the above categories of recipients are providing us with services that involve them processing personal data on our behalf, they are our data processor.

6. International Transfers

We’re based in the UK, but sometimes your personal information may be transferred by us or our data processors to countries outside the UK and EEA. Where this is the case, we will ensure that it will only be transferred to countries that have been identified as providing adequate protection for personal data, or to a third party where we have approved a transfer mechanism in place to protect your personal data – for example, by requiring the service provider to enter into Standard Contractual Clauses.

7. Data Security

We have put in place appropriate technical and organisational security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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

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, tax, 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, tax, accounting or other requirements.

Generally, in respect of customer information, our retention period is 6 years following the end of our relationship with you. Marketing and communications data will generally be held for 2 years following the last active interaction with you.

Upon expiry of the applicable retention period, we will securely destroy your personal data in accordance with applicable laws and regulations.

9. Your Legal Rights

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

Request access to your personal data

This is 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 your personal data

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 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

This enables you to object 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, although this does not apply where you object to our processing for direct marketing purposes.

Request restriction of processing your personal data

This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy (b) where our use of the data is unlawful but you do not want us to erase it (c) where you need us to hold the data even if we no longer require it as you need to establish, exercise or defend legal claims or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request transfer of your personal data

This enables you to request the transfer of your personal data to you or to a third party in a structured, commonly used, machine-readable format. Note that this right only applies to personal data that is processed by automated means where we are relying on consent or performance of a contract as the legal basis for the processing.

Right to withdraw consent

This enables you to withdraw consent at any time where we are relying on consent as the legal basis for processing your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

Right to complain to a supervisory authority

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. The relevant supervisory authority in the UK is the Information Commissioner’s Office (ICO). Go to ico.org.uk/concerns to find out more. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

If you wish to exercise any of the rights set out above, please contact us. 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.

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.

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.

Effective Date: 12/10/23