La Modesta Limited understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, www.lamodest.co.uk (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner 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 Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;]
“personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”)
“We/Us/Our” means London Tea Exchange Limited T/A London Tea Exchange a limited company registered in England under company number 08494048, whose registered address, and main trading address is 103, Brick Lane, LONDON E1 6SE.
2.INFORMATION ABOUT US:
2.1 Our Site is owned and operated by La Modesta Limited, a limited company registered in England.
3.WHAT DOES THIS POLICY COVER:
4. YOUR RIGHTS:
4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 The right to be informed about our collection and use of personal data;
4.1.2 The right of access to the personal data We hold about you (see section 5);
4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 2);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to Us using your personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.
4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 2 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5. WHAT DATA DO WE COLLECT:
5.2 date of birth;
5.4 business/company name
5.5 job title;
5.7 contact information such as email addresses and telephone numbers;
5.8 demographic information such as post code, preferences, and interests;
5.9 financial information such as credit / debit card numbers;
5.10 IP address;
5.11 web browser type and version;
5.12 operating system;
5.13 a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;
6. HOW DO WE USE YOUR DATA?:
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 8, below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
6.2.1 Providing and managing your Account;
6.2.2 Providing and managing your access to Our Site;
6.2.3 Personalising and tailoring your experience on Our Site;
6.2.4 Supplying Our products and or services to you (please note that We require your personal data in order to enter into a contract with you);
6.2.5 Personalising and tailoring Our products and or services for you;
6.2.6 Replying to emails from you;
6.2.7 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by emailing us requesting opt out -or use the links at the foot of the email for instant removal from our system.
6.2.8 In order to market to you via social media platforms and to enable social sharing and engagement on our website
7. MARKET RESEARCH:
Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
7.1 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email and or telephone and or text message and or post with information, news and offers on Our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
7.2 Third parties, (including Google Analytics,) whose content appears on Our Site - may use third party Cookies, as detailed below in section 13. Please refer to section 13 for more information on controlling Cookies. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.
7.3 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
7.4 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data retention will be determined on the following bases:
7.5 The length of time we keep your personal data depends on what it is and whether we have an ongoing business and need to retain it (for example, to provide you with a service you’ve requested or to comply with applicable legal, tax or accounting requirements. We’ll retain your personal data for as long as we have a relationship with you and for a period of time afterwards where we have ongoing business and need to retain it. Following that period, we’ll make sure it’s deleted or anonymised.
8. HOW AND WHERE DO WE STORE YOUR DATA? :
8.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
8.2 Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR including:
8.2.1 All London Tea Exchange uses a combination of data centres and cloud service providers to store this personal data in the EU as well as United States and Canada. When personal data is transferred to the United States, it is either done so through the EU-U.S. and Swiss-U.S. Privacy Shield, or through contractual data protection addenda (DPAs) with third-party service providers. The EU-U.S. and Swiss-U.S. Privacy Shields are also considered adequate under the GDPR. Find out more at PrivacyShield.gov
8.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
8.4 Steps We take to secure and protect your data include:
8.4.1 London Tea Exchange encrypts data sent to and from merchants and buyers using the HTTPS protocol. We also encrypt sensitive stored information, and salts and hashes merchant and buyer passwords using bcrypt. The London Tea Exchange checkout system is Level 1 PCI-DSS compliant
8. ANALYTICS :
Our Site uses analytics services provided by Google Analytics and Heap Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the products and /or services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
9.1 The analytics service(s) used by Our Site use(s) the following Cookies above:
9.2 In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
9.3 You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
9.4 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
10. CONTACTING US:
3.2 By using Our Site, you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. Third parties, (such as Google Analytics,) whose content appears on Our Site - may use third 3.3 All Cookies used by and on Our Site are used in accordance with current Cookie Law. We may use some or all of the following types of Cookie:
3.3.1 Strictly Necessary Cookies
A Cookie falls into this category if it is essential to the operation of Our Site, supporting functions such as logging in, your shopping basket, and payment transactions.
3.3.2 Analytics Cookies
It is important for Us to understand how you use Our Site, for example, how efficiently you are able to navigate around it, and what features you use. Analytics Cookies enable us to gather this information, helping Us to improve Our Site and your experience of it.
3.3.3 Functionality Cookies
Functionality Cookies enable Us to provide additional functions to you on Our Site such as personalisation and remembering your saved preferences. Some functionality Cookies may also be strictly necessary Cookies, but not all necessarily fall into that category.
3.3.4 Targeting Cookies
It is important for Us to know when and how often you visit Our Site, and which parts of it you have used (including which pages you have visited and which links you have visited). As with analytics Cookies, this information helps us to better understand you and, in turn, to make Our Site and advertising more relevant to your interests. Some information gathered by targeting Cookies may also be shared with third parties.
3.3.5 Third Party Cookies
Third party Cookies are not placed by Us; instead, they are placed by third parties that provide services to Us and/or to you. Third party Cookies may be used by advertising services to serve up tailored advertising to you on Our Site, or by third parties providing analytics services to Us (these Cookies will work in the same way as analytics Cookies described above).
3.3.6 Persistent Cookies
Any of the above types of Cookie may be a persistent Cookie. Persistent Cookies are those which remain on your computer or device for a predetermined period and are activated each time you visit Our Site.
3.3.7 Session Cookies
Any of the above types of Cookie may be a session Cookie. Session Cookies are temporary and only remain on your computer or device from the point at which you visit Our Site until you close your browser. Session Cookies are deleted when you close your browser.
3.4 Cookies on Our Site are not permanent and will expire within two years or less
3.6 For more specific details of the Cookies that We use, please refer to the table below.
3.7 Our Site uses analytics services provided by google analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the products and services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
3.8 The analytics service(s) used by Our Site use(s) analytics Cookies to gather the required information.
3.9 The analytics service(s) used by Our Site use(s) the following analytics Cookies:
Name of Cookie
4. CONSENT AND CONTROL
4.2 In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
4.3 The links below provide instructions on how to control Cookies in all mainstream browsers:
4.3.1 Google Chrome: https://support.google.com/chrome/answer/95647?hl=en-GB
4.3.2 Microsoft Internet Explorer: https://support.microsoft.com/en-us/kb/278835
4.3.3 Microsoft Edge: https://support.microsoft.com/en-gb/products/microsoft-edge (Please note that there are no specific instructions at this time, but Microsoft support will be able to assist)
4.3.4 Safari (macOS): https://support.apple.com/kb/PH21411?viewlocale=en_GB&locale=en_GB
4.3.5 Safari (iOS): https://support.apple.com/en-gb/HT201265
4.3.6 Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-Cookies-website-preferences
4.3.7 Android: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DAndroid&hl=en (Please refer to your device’s documentation for manufacturers’ own browsers)
6. FURTHER INFORMATION
6.2 For more information about privacy, data protection and our terms and conditions, please visit the following section of our website