If we have asked you to provide certain information by which you can be identified when using this website, you can be assured that it will only be used lawfully (in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”)), as set out in this Policy.
By visiting www.smallbeer.co, you are accepting and consenting to the practices described in this Policy. Incubator Kitchen may change this Policy from time to time by updating this page. Please check this page from time to time to ensure that you are happy with any changes.
If you have any questions about this Policy, including any requests to exercise your legal rights, please contact us using the details set out below.
Email address: firstname.lastname@example.org
Other than in accordance with any contract you have with Incubator Kitchen, Incubator Kitchen is the controller and responsible for your Personal Data (collectively referred to as “Incubator Kitchen”, “we”, “us” or “our” in this Policy).
What we collect
Personal Data, or personal information, means any information about an individual from which that person can be identified. It does not include anonymous data, where an individual’s identity has been removed.
We may collect, use, store and transfer different kinds of Personal Data about you, such as:
Identity Data – including first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender and job title;
Contact Data – including billing address, delivery address, email address and telephone numbers;
Profile Data – including your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses;
Registration Data – including newsletter requests, event/seminar registrations, dietary preferences (excluding special categories of data), subscriptions, and downloads;
Client Service Data – including Personal Data received from clients in respect of employees, customers or other individuals known to clients, invoicing details and payment history, and client feedback;
Technical Data – including internet protocol (IP) address, your 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 you use to access this website;
Financial Data – including bank account and payment card details;
Transaction Data – including details about payments to and from you and other details of services or products you have purchased from us;
Compliance data – Government identifiers, passports or other identification documents, dates of birth, beneficial ownership data and due diligence data;
Usage Data – including information about how you use our website, products and services; and
Marketing and Communications Data – including your preferences in receiving marketing from us and our third parties and your communication preferences.
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. 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 Policy.
We do not collect any Special Categories of Personal Data about you, including 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.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that the Personal Data we hold about you is accurate and current. Please keep up informed if your Personal Data changes during your relationship with us.
By using our website, you (the visitor) agree to allow third parties to process your IP address, in order to determine your location for the purpose of currency conversion. You also agree to have that currency stored in a session cookie in your browser (a temporary cookie which gets automatically removed when you close your browser). We do this in order for the selected currency to remain selected and consistent when browsing our website so that the prices can convert to your (the visitor) local currency.
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, when you initially engage with our services but you do not provide relevant identification documents that would allow us to comply with anti-money laundering checks, we may refuse to carry out our services to you. In such cases, we will notify you at the time.
What we do with the information we gather
We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:
to register you as a new client;
to provide and improve our services and respond to enquiries;
to process and deliver payments including:
notifying you about changes to our terms or policies; and/or
asking you to leave a review or take a survey;
to periodically send promotional emails about changes in the law, invitations to seminars or ideas which we think you may find interesting using the email address which you have provided;
from time to time, to contact you for market research purposes, by email, phone, fax or mail;
to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
to use data analytics to improve our website, products and/or services, marketing, customer relationships and experiences;
to make suggestions and recommendations to you about goods or services that may be of interest to you; and
to deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
We may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need more details about the specific legal ground we are relying on to process your Personal Data.
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.
Third Party Transfers
We may have to share your Personal Data with third parties:
IT and system administration service providers acting as processors;
Service providers who assist and support Incubator Kitchen with running our website or other IT services;
Payment services providers;
Some of our consultants and lawyers, as well as professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers; and
HMRC, regulators and other authorities acting as processors or joint controllers.
This may involve transferring your data outside of the European Economic Area (EEA). Whenever we transfer your Personal Data out of the EEA, we ensure a similar degree of protection is afforded to it by implementing at least one of the following safeguards:
We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give Personal Data the same protection it has in Europe.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to Personal Data shared between Europe and the US.
We may also have to share your Personal Data for the above purposes with 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 Policy.
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, or to take steps at your request before entering into such a contract;
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. 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; and
where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your Personal Data other than in relation to sending third party direct marketing communications to you via email, phone, fax or mail.
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 by post, phone, email or otherwise. This includes Personal Data you provide when you apply for our services, fill out a new enquiry form on our website, subscribe to our service or publications, request marketing to be sent to you, enter a competition, promotion or survey and/or give us some feedback.
Automated technologies or interactions – as you interact with our website, we may 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.
Third parties or publicly available sources – we may receive Personal Data about you from various third parties and public sources such as:
Technical Data from analytics providers such as Google based outside the EU and/or search information providers based inside or outside of the EU;
Contact, Financial and Transactional Data from providers of technical, payment and delivery services based inside the UK/EU; and
Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK/EU.
How long and where we store your data
We will keep your Personal Data for as long as we need to in order to use it as described above, and/or for as long as we have your permission to keep it. The purposes include 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.
In some circumstances we may 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.
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
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 will never sell, distribute or lease your personal information to third parties.
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
Links to other websites
Our website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this Policy. We encourage you to read the privacy statement applicable to any website you visit.
Marketing and Opting Out
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 to you (we call this marketing). You will receive marketing communications from us if you have requested information from us, purchased goods or services from us, signed up to our newsletters or blogs, provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing. You have the right to withdraw consent to marketing at any time by contacting us.
You can ask us to stop sending you marketing messages by contacting 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 a service purchase, service experience or other transactions.
Exercising your rights
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:
the right to be informed about our collection and use of Personal Data;
the right of access to the Personal Data we hold about you;
the right to rectification if any Personal Data we hold about you is inaccurate or incomplete;
the right to be forgotten – i.e. the right to ask us to delete any Personal Data we hold about you;
the right to restrict the processing of your Personal Data;
the right to data portability – i.e. obtaining a copy of your Personal Data to re-use with another service or organisation;
the right to object to us using your Personal Data for particular purposes; and
rights with respect to automated decision making and profiling.
If you wish to exercise any of these rights, please contact us. Please note that 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.
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 may refuse to comply with your request in these circumstances.
We try to respond to all legitimate requests within one month. Occasionally it may 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.
If you have any cause for complaint about our use of your Personal Data, please contact us 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 for data protection issues, the Information Commissioner’s Office (www.ico.org.uk).