Privacy Policy

SMALL BEANS LTDPRIVACY POLICYLast updated: 10 August 20201. ABOUT THIS PRIVACY POLICY1.1 The website small-beans.co.uk (the Site) is operated by SMALL BEANS LTD (“we”, “us”, “our”), a company incorporated in England and Wales under company number 12801551. Our registered office is at Kemp House, 160 City Road, London, EC1V 2NX . 1.2 We are committed to protecting your privacy and complying with our data protection obligations under the Data Protection Act 2018 (the DPA 2018), the General Data Protection Regulation 2016/679 (the GDPR) and any other applicable UK legislation (together, Data Protection Law).1.3 When you interact with us or use the Site, we act as the data controller of your personal data. This means that we are responsible for processing your personal data and deciding how to use it. This privacy policy explains the types of personal data we may collect about you when you interact with us, why we collect it, what we use it for and what rights you have over that data. Personal data is any information about an identifiable person. Processing is anything we do with your personal data, including using, storing, sharing and deleting it.1.4 This policy was last updated on the date shown at the top. We may change this policy at any time by posting an updated version on the Site and will make reasonable efforts to bring any material changes to your attention. You may wish to check it before using the Site as any changes will be effective from the date that they are made. 2. CONTACT INFORMATION2.1 If you have any concerns or would like further information about our use of data or this policy in general, you can contact our David Burnett at .ku.oc.snaeb-llams%40troppus 3. WHAT INFORMATION DO WE COLLECT?3.1 We collect, store and use the types of personal data set out in the table at the end of this policy.4. HOW WILL WE USE YOUR PERSONAL DATA?4.1 We will use your personal data for the purposes set out in the table at the end of this policy.5. HOW DO WE SHARE YOUR PERSONAL DATA?5.1 When we share personal data, we do so in accordance with Data Protection Law. We may share certain personal data, where necessary, with employees, contractors, consultants or advisers, to facilitate sales and for general commercial purposes.In addition, where necessary, your personal data may be shared:5.1.1 with government or quasi-governmental organisations, law enforcement and other regulatory authorities or third parties when required or permitted by law, including but not limited to in response to court orders, for the prevention and detection of crime and to protect intellectual property and any other legal rights.5.1.2 if the company or business is sold, transferred or integrated with another business, with our advisers, a prospective purchaser, a prospective purchaser’s advisers or the new owner of the company or business to facilitate the process.5.2 We may also provide third parties with aggregated but anonymised information and analytics about our customers. Before we do so we will make sure that it does not identify you.6. THIRD PARTY LINKS6.1 This Site contains links to other websites over which we have no control. We are not responsible for and do not review or endorse the privacy policies or practices of other sites which you choose to access from this Site. We encourage you to review the privacy policies of those other sites, so you can understand how they collect, use and share your personal information.7. YOUR RIGHTS7.1 We respect your rights to privacy and will respond to requests for access or control over information about you in accordance with Data Protection Law. We may require you to verify your identity before we take any action.7.2 Depending on the reason we have your personal data, you have a right to:7.2.1 access the personal information we hold about you (commonly known as subject access);7.2.2 request that we correct or complete personal information we hold about you that is inaccurate or incomplete; 7.2.3 request that we erase your personal information in some circumstances, or object to our processing it as detailed at paragraph 7.5; 7.2.4 restrict how we use your personal information, in certain circumstances; 7.2.5 request that we provide you with copies of your personal information in a machine-readable format or transfer it across different services; and7.2.6 where we have asked for your consent to process your data, to withdraw this consent.7.3 These rights are limited in some situations under Data Protection Law – for example, where we can demonstrate that we are under a legal obligation to process your data.7.4 If you wish to exercise any of these rights, please contact us using the details in paragraph 2 above. 7.5 Your right to object You have a right to object to our processing of your personal data and ask us to stop doing so. If we are processing your personal data for direct marketing purposes (which includes profiling to the extent that it is related to such direct marketing) and you object to this, we will stop processing your personal data immediately.If our processing of your personal data is in the public interest or pursuant to our legitimate interests and you object to this, we will stop processing your personal data unless we have compelling reasons which override your interests, or our use of your personal data is for the establishment, exercise or defence of legal claims.7.6 We hope that we can satisfy any queries you may have about the way we process your data. However, if you have unresolved concerns you also have the right to complain to data protection authorities (in the UK, the Information Commissioner’s Office). You can call the ICO on 0303 123 1113 or go to their website: https://ico.org.uk/make-a-complaint/).8. DATA RETENTION8.1 Your personal data will only be kept for as long as necessary for our purposes. Specific periods are set out in the table at the end of this policy.9. DATA PROTECTION PRINCIPLES9.1 We process your personal data in accordance with the following principles: 9.1.1 we process your personal data lawfully, fairly and in a transparent way; 9.1.2 we collect your personal data for specified, explicit and legitimate purposes; any further processing we do is compatible with the original purposes for which for which we collected it;9.1.3 we only process personal data which is adequate, relevant and limited to what is necessary to achieve the purpose for which it is processed; 9.1.4 we take reasonable steps to ensure that all personal data is accurate and kept up to date where necessary;9.1.5 we do not store personal data in a form which identifies you for any longer than is necessary for the purposes of processing; and9.1.6 we process personal data securely and in a way that protects against unauthorised or unlawful processing, accidental loss, destruction or damage. 9.2 When we ask for your personal data we will tell you whether you are required by law or contract to provide it, and what will happen if you do not provide the data. 9.3 Any request for consent to the processing of your personal data will be made directly to you and will include information about why we require the personal data and what will be done with it.10. WHAT IS OUR LAWFUL BASIS FOR PROCESSING?10.1 We will only process personal data when we have a lawful basis for doing that processing. The table at the end of this policy sets out the lawful basis we rely on for each type of data we process.10.2 We will choose one of the lawful bases in the GDPR to justify how we use your personal data. These are:10.2.1 Consent: You have given consent to the processing of your personal data for one or more specific purposes.10.2.2 Contract: The processing is necessary for the performance of a contract with you or in order to take steps at your request before entering into a contract.10.2.3 Legal obligation: We need to process your personal data to comply with a legal obligation.10.2.4 Vital interests: The processing is necessary to protect the vital interests of you or another person.10.2.5 Public interest: Processing is necessary for the performance of a task carried out in the public interest or in the exercise of some official authority.10.2.6 Legitimate interests: Processing is necessary for the purposes of legitimate interests pursued by us or someone else, except where such interests are overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.
11. ATTRIBUTION11.1 This privacy policy was created using a template from Sparqa Legal (https://www.sparqa.com), August 10, 2020.
 




TABLE OF PERSONAL INFORMATION

The table below sets out detailed information about our purposes for processing, the basis for processing and the retention period for the personal data.

    • Category of personal data

    • Purpose of processing

    • Lawful basis for processing

    • Retention period

    • Category of personal data

    • Category of personal data

    • Purpose of processing

    • Purpose of processing

    • Lawful basis for processing

    • Lawful basis for processing

    • Retention period

    • Retention period

    • Name and contact details

    • To deliver & ensure continuity of your service 
      To send you updates on the status of your service
      For fraud prevention and detection
      To contact you with information, newsletters and marketing materials about our products and services

    • Performance of contract

      Compliance with legal obligation

      Consent

    • For the period of your contract with Small Beans LTD and 3 months following in case retention of service is required, or until you withdraw consent if earlier

    • Category of personal data

    • Name and contact details

    • Purpose of processing

    • To deliver & ensure continuity of your service 
      To send you updates on the status of your service
      For fraud prevention and detection
      To contact you with information, newsletters and marketing materials about our products and services

    • Lawful basis for processing

    • Performance of contract

      Compliance with legal obligation

      Consent

    • Retention period

    • For the period of your contract with Small Beans LTD and 3 months following in case retention of service is required, or until you withdraw consent if earlier

    • Payment information

    • To take payment and give refunds

      For fraud prevention and detection

    • Performance of contract

      Compliance with legal obligation

    • For three years since your last purchase

    • Category of personal data

    • Payment information

    • Purpose of processing

    • To take payment and give refunds

      For fraud prevention and detection

    • Lawful basis for processing

    • Performance of contract

      Compliance with legal obligation

    • Retention period

    • For three years since your last purchase

    • Contact history

    • To provide customer service and support

      To train our staff

    • Performance of contract

      Legitimate interests in dealing with complaints or claims

    • For three years since your last contact

    • Category of personal data

    • Contact history

    • Purpose of processing

    • To provide customer service and support

      To train our staff

    • Lawful basis for processing

    • Performance of contract

      Legitimate interests in dealing with complaints or claims

    • Retention period

    • For three years since your last contact

    • Purchase history

    • To provide customer service and support and handle returns, refunds and rebates
      To find out whether you are applicable for any eligible discounts on future services

    • Performance of contract

      Consent

    • For three years since you gave consent, or until you withdraw consent if earlier

    • Category of personal data

    • Purchase history

    • Purpose of processing

    • To provide customer service and support and handle returns, refunds and rebates
      To find out whether you are applicable for any eligible discounts on future services

    • Lawful basis for processing

    • Performance of contract

      Consent

    • Retention period

    • For three years since you gave consent, or until you withdraw consent if earlier

    • Browser, device and Site usage information

    • To improve your Site experience

      To protect the Site against fraud

      To set default options for you, such as language and currency

    • Performance of contract

      Legitimate interest in maintaining our Site

    • This data is anonymised and stored indefinitely

    • Category of personal data

    • Browser, device and Site usage information

    • Purpose of processing

    • To improve your Site experience

      To protect the Site against fraud

      To set default options for you, such as language and currency

    • Lawful basis for processing

    • Performance of contract

      Legitimate interest in maintaining our Site

    • Retention period

    • This data is anonymised and stored indefinitely

    • Responses to surveys, competitions and promotions

    • To run the survey, competition or promotion

    • Performance of contract

      Legitimate interest in dealing with complaints or claims and improving our products and/or services generally

    • For three years

    • Category of personal data

    • Responses to surveys, competitions and promotions

    • Purpose of processing

    • To run the survey, competition or promotion

    • Lawful basis for processing

    • Performance of contract

      Legitimate interest in dealing with complaints or claims and improving our products and/or services generally

    • Retention period

    • For three years

    • Customer comments and product reviews

    • To improve our products and services

      Where relevant, to establish, exercise or defend legal claims

    • Performance of contract
      Legitimate interest in dealing with complaints or claims and improving our products and/or services generally

    • Indefinitely unless consent is withdrawn at any time

    • Category of personal data

    • Customer comments and product reviews

    • Purpose of processing

    • To improve our products and services

      Where relevant, to establish, exercise or defend legal claims

    • Lawful basis for processing

    • Performance of contract
      Legitimate interest in dealing with complaints or claims and improving our products and/or services generally

    • Retention period

    • Indefinitely unless consent is withdrawn at any time

    • Information collected through cookies and similar technologies

    • To conduct and store site usage analytics, statistical and trend analysis and market research

      To generate customer profiles to facilitate marketing initiatives

    • Consent

    • For three years since you gave consent, or until you withdraw consent if earlier

    • Category of personal data

    • Information collected through cookies and similar technologies

    • Purpose of processing

    • To conduct and store site usage analytics, statistical and trend analysis and market research

      To generate customer profiles to facilitate marketing initiatives

    • Lawful basis for processing

    • Consent

    • Retention period

    • For three years since you gave consent, or until you withdraw consent if earlier