PRIVACY STATEMENT

Welcome to our privacy statement.

Summary


We respect your privacy, and we are committed to protecting your personal data. This privacy statement will explain how we use and look after your personal data when you are a customer or you:
•    Visit our website:  (regardless of where you visit it from).
•    [Use any of our apps.]
•    [Call us, write to us or communicate with us in any way.
•    [Visit our premises].

This privacy statement does not apply to you if you work for us or are applying to work for us. In that case, we will provide separate privacy statements that set out that relationship with you. [For example, if you use our job application forms via the links on our website.]

This privacy statement also tells you about your privacy rights and how the law protects you.

When we say “we”, “us” or “TLC”, that means the company “TLC – Tender Loving care UK Ltd”. When we say Chewy Vites  that refers to the product and brand that is owned by TLC. 

Where we collect information about you, if that information is about you, or can be used by us or organisations with which we work to find out about you, it is known as “personal data”.

In line with the law, this privacy statement tells you what types of personal data we hold about you, what we use it for, why we are allowed to use it in that way and what your legal rights are.

The rules about personal data are complex. If you need help understanding anything in this privacy statement, please contact us at info@cheywvites.com.

The simple version is this:
•    We collect information about you, including contact details (like your email address), when you give us that information on our website and when you call us or communicate with us. [We also collect other information, for example, [via cameras at our offices to make sure that our premises are safe places].]
•    We treat the information that we hold about you very carefully. We do our best to make sure that information about you does not go to the wrong people or to people who might not look after that information properly.
•    If you ask us to do certain things with the information that we hold about you, we must usually do what you ask and you do not usually have to pay for this. Those things include:
o    Giving you a copy of the information that we hold about you.
o    Putting right any mistakes in the information that we hold about you.
o    Stopping using information about you or deleting it.
If you want to ask us to do any of these things, or you have any questions or concerns, you can contact us at info@chewyvites.com. If you still have concerns, you can also contact the Information Commissioner’s Office (“ICO”). This is the organisation in charge of making sure that we do the right things with your personal data.

BACKGROUND
This privacy statement is addressed to individuals who visit the [premises or website[s] operated by] TLC – Tender Loving Care UK Ltd (“TLC”, “we”, “our” or “us”); to our customers; and to other individuals who may deal with us, including individuals at our suppliers. In this privacy statement, we collectively refer to these categories of individuals as “you”.

If you are applying to work for us, or you are one of our staff members or workers, a different privacy statement will apply. In that case, we will provide a separate privacy statement that sets out that relationship with you.

Our privacy statement is split into linked sections so that you can quickly go to a specific section. Alternatively, if you prefer, you can contact us to request a hard copy of the whole privacy statement.

You can check the meaning of some of the terms used in this privacy statement by using the Glossary in the final section.


1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW YOUR PERSONAL DATA IS COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL DATA TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY


1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy statement

This privacy statement details how TLC – Tender Loving Care UK Ltd collects and processes your personal data when you are a customer or you:
•    Visit our website: www.chewyvites.com (regardless of where you visit it from).
•    [Use any of our apps.]
•    [Call us, write to us or communicate with us in any way.]
•    [Visit our premises.]

This privacy statement does not apply to you if you work for us or are applying to work for us. In that case, we will provide separate privacy statements that set out that relationship with you. [For example, if you use our job application forms via the links on our website.]

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

To ensure that you are fully aware of how and why we are using your data, it is important that you read this privacy statement together with any other data protection or privacy statement that we may provide on specific occasions when we are collecting or processing personal data about you. This privacy statement supplements other such statements and privacy policies, and is not intended to override them.

Controller

TLC – Tender Loving Care UK Ltd (referred to as “TLC”, “we”, “us” or “our” in this privacy statement), a limited company registered in England and Wales with registered company number 03495854 and whose registered head office is at 73 Cornhill London, EC3V 3QQ, is the controller and is responsible for your personal data.

This privacy statement is issued on behalf of TLC. If your communications with us relate to our other group companies, we will pass your personal data to them so that they can handle your enquiry. Their privacy statement will also apply to how they process your personal data.

Contact details

If you have any questions about this privacy statement (including any requests to exercise your legal rights) or about our privacy practices, please contact our Data Privacy Manager in the following ways:

Email address: info@chewyvites.com

Postal address: 73 Cornhill London, EC3V 3QQ

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. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so we would encourage you to contact us first to discuss these.

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

We keep our privacy statement under regular review. This version was last updated on 18th June 2021 Historic versions can be obtained by contacting us.
Any changes that we make to this privacy statement in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy statement.
It is important that the personal data that 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

Our website may include links to third-party websites, social media platforms, plug-ins and applications, for your convenience and information. Clicking these links or enabling those connections means that you may leave our website and may allow third parties to collect or share data about you.

We do not control these third-party websites, social media accounts or apps. We are not responsible, or liable, for how they process your personal data or for their privacy statements. For example, they may send their own cookies to users, collect data or solicit personal data from you. When you leave our website, we encourage you to read the privacy statement of every website, app and social media account that you use or visit.

[If you are applying to work for us, you may be asked to complete an online application form. This form is provided by a recruitment software provider. All personal data that you provide via that form is stored on our systems, and the provider does not access or otherwise process that information.]

2. THE DATA WE COLLECT ABOUT YOU

When you contact us through our website, communicate with us or visit our premises, you may provide us with personal data about you.
Personal data 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 the following kinds of personal data about you:
·    Identity data includes your [first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender].
·    Contact data includes your [billing address, delivery address, email address and telephone numbers].
·    [Financial data includes your [bank account and payment card details].]
·    [Transaction data includes [details about payments to and from you and other details of products and services that you have purchased from us].]
·    Technical data includes your [IP address, 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 that you use to access our website].
·    [Profile data includes your [username and password, purchases or orders made by you and your interests, preferences, feedback and survey responses].]
·    Usage data includes information about how you use our website, products and services.
·    [Image data includes individual images or general location images in which you might be visible.]
·    [CCTV data includes images and video recordings that may contain personal data that have been collected by our CCTV systems at our premises.]
·    [Accident and incident data includes details about accidents or incidents that have occurred on our premises.] 
·    Marketing data includes [your preferences in receiving marketing from us and our third parties, and your communication preferences].
·    Communications data includes personal data that is included in your communications with us.

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 because this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users who access 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 statement.

[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). We also do not 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 that we have with you, or we are processing your personal data to fulfil a request that you have made, and you fail to provide that data when requested, we may not be able to perform the contract that we have or are trying to enter into with you (for example, to provide you with goods or services) or we may not be able to otherwise comply with your request. In this case, we may have to cancel a product or service that you have with us, but we will use reasonable efforts to notify you if this is the case at the time.

3. HOW YOUR PERSONAL DATA IS COLLECTED

We use different methods to collect data from and about you, including through:
•    Direct interactions. You may give us your [identity data, contact data and financial data] by filling in forms or by corresponding with us by post, phone, email, social media or otherwise. This includes personal data that you provide when you:
o    Enquire about our products or services.
o    Create an account on our website.
o    Subscribe to our services or publications.
o    Request marketing to be sent to you.
o    Enter a competition or promotion, or complete a survey.
o    Give us feedback or contact us.
•    [CCTV systems. We may collect CCTV data where our group company, TLC, operates and manages CCTV on our behalf at our premises.]
•    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 that employ our cookies.] Please see our cookie policy for further details.
·    Third parties or publicly available sources. We will receive personal data about you from various third parties [and public sources] as set out below:
o    Technical data from the following parties:
(a)    Analytics providers such as [Google].
•    Marketing data. We collect your contact data if you make an enquiry via [our marketing services provider.] [/][We do not buy in mailing lists.][one of our group companies, and that enquiry is dealt with by, or we need to pass you to, another group company.]
•    [Other third parties [and public sources].]

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:
•    Where we need to perform the contract that 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.

To find out more about the types of lawful basis that we will rely on to process your personal data, see the Glossary below.

Generally, we do not rely on consent as a legal basis for processing your personal data. However, we will request 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.

Purposes for which we will use your personal data

The following table describes all the ways in which we plan to use your personal data, and which of the legal bases we rely on to do so. Where appropriate, we have also identified what our legitimate interests are.

Note that we may process your personal data on more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis on which we are relying to process your personal data where more than one basis has been set out in the table below.

Purpose/activity

Type of data

Legal basis for processing (including the relevant legitimate interest basis where applicable) 

Retention period

To register you as a new customer

(a) Identity

(b) Contact

Performance of a contract with you

 

To process and deliver your order including:

(a) Managing payments, fees and charges

(b) Collecting and recovering money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing

(f) Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

 

To manage our relationship with you, which will include:

(a) Responding to an enquiry or complaint

(b) Notifying you about changes to our terms or privacy statement

(c) Asking you to supply a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing

(e) Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products and services)

 

To enable you to partake in a prize draw or competition, or complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing

(f) Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products and services, to develop them and to grow our business)

 

To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(d) Communications

(a) Necessary for our legitimate interests (for running our business, for provision of administration and IT services, for network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

 

To deliver relevant content and advertisements to you, and measure or understand the effectiveness of the advertising that we provide

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing

(f) Communications

(g) Technical

Necessary for our legitimate interests (to study how customers use our products and services, to develop them, to grow our business and to inform our marketing strategy)

 

To use data analytics to improve our website, products and services, marketing and customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

 

To make suggestions and recommendations to you about goods or services that may be of interest to you 

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Marketing

(f) Communications

Necessary for our legitimate interests (to develop our products and services, and to grow our business)

 

CCTV

CCTV

Necessary for our legitimate interests (to manage the security of our premises, to manage health and safety at our premises, and to allow us to manage insurance claims )

 

[To complete reports about accidents or incidents that are reported to us] 

  1. [Identity
  2. Contact
  3. Accident and incident]
  1. [Legitimate interest
  2. Necessary to comply with a legal obligation]

 

[Insert other activities to align with activities identified elsewhere in this privacy statement.]

  1.  [Insert]

[Insert]

 


 

Automated decision-making

We do not make any decisions that could have a legal effect, or other significant effect on you, based solely on automated processing of your personal data.

Marketing

[We hope that you enjoy and value our newsletter and updates, and our marketing material generally. We may send you this information by various means including email, text message, post or telephone. We respect your right to choose what marketing messages you receive , and we will always try 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

Our website is designed to provide information about our organisation. If you make an enquiry with us about another group company (see above), we will pass your enquiry to the appropriate group company so that they can contact you directly, including for their own marketing purposes. We do not otherwise share your personal data with any third party for marketing purposes.

Opting out

You can ask us to stop sending you marketing messages at any time by selecting or deselecting relevant boxes to adjust your marketing preferences. You can also follow the opt-out links on any marketing message that we email to you or contact us  at any time.

[Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of product/service purchase or experience, warranty registration or other transactions. ]

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 our website may become inaccessible or not function properly. For more information about the cookies that 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 would like to understand more about any of our purposes, or you wish us to explain 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 explain the legal basis that 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.

  1. Disclosures of your personal data

All of our contractors, suppliers and staff (including volunteers, agents, temporary workers and casual workers) who process your personal data on our behalf (and therefore act as our processors) are subject to strict contractual requirements in relation to processing personal data.

We may share your personal data with the following parties for the purposes set out in the table in the previous section.

  • Internal third parties as set out in the Glossary .
  • 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, the new owners may use your personal data in the same way as set out in this privacy statement.

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. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

  1. International DATA transfers

[We do not transfer your personal data outside the United Kingdom or the European Economic Area (“EEA”) unless your enquiry relates to one of our group companies that is based outside the UK or the EEA. See here for details on where our group companies are located, or where you contact us from outside the UK or the EEA.[S15] 

We will only transfer your personal data to countries that the UK government or the European Commission have deemed to provide an adequate level of protection for personal data. For further details, see the information about adequacy decisions on the European Commission’s website and the UK ICO website).

Where we use certain service providers, we may use specific contracts approved by the European Commission that give personal data the same protection that it has in Europe. For further details, see the information about model contracts for the transfer of personal data to third countries on the European Commission’s website and the UK ICO website.

Please contact us if you would like further information about the specific mechanism that we use when we transfer your personal data out of the UK or the EEA.]

Please note that we have no control over the routes that emails take, and even emails exchanged between two people in the UK could appear on equipment in countries outside the UK or the EEA, where they may not be protected by strong privacy or data protection laws.

  1. Data security

We have a strong commitment to 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.

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 take appropriate steps to communicate with and train our staff in relation to applicable data protection law.

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

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to or via our website. Any transmission is at your own risk.

Use of CCTV data is subject to additional specific rules and protections, as described more fully in our CCTV policy, which is available on request.

If you would like to know more about our data security measures, please contact us.

  1. Data retention 

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes for which we collected it, 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 that 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.

[Details of retention periods for different aspects of your personal data are available in our retention policy, which you can request from us by contacting us/as set out above.]

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 the following section 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.

  1. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data, which we process as a controller. These rights are subject to specific requirements and limitations set out in the applicable data protection legislation and are summarised below:

  • You can request access to the personal data that we hold about you and check that it is being lawfully processed (commonly known as a “data subject access request”).
  • You can request correction of the personal data that we hold about you if it is wrong and ask us to complete it if it is incomplete.
  • You can request erasure of your