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Cremoloso Gelato Ltd Privacy Policy

This privacy policy sets out how Cremoloso Gelato Ltd collects and processes your personal data through your use of our website www.cremolosogelato.co.uk, by your use of any social media platforms run by Cremoloso Gelato Ltd, including any information you may provide through our site or via social media or any other platform run by Cremoloso Gelato Ltd, as well as information you may provide via email, letter, face to face or on the telephone.
Cremoloso Gelato Ltd may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 20/12/2020.
By providing us with your data, you warrant to us that you are over 13 years of age.
The Cremoloso Gelato Ltd (referred to as “we”, “us” or “our” in this privacy policy) is the data controller and we are responsible for your personal data.
What data do we collect, for what purpose and on what grounds will it be processed
Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may process the following categories of personal data about you:

- Communication Data includes any communication that you send to us, whether via the contact form on our website, by email, social media messaging, text messages, social media posting, by post or any other communication that you send to us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this is legitimate interest.
- Customer Data includes data relating to any purchases of goods and/or services. Data includes your title, name, billing address, delivery address, email address, phone number, other contact details and any purchase details. We process this data to supply any goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for processing this information is contract, to enable us to carry out a contract between us and you and/or legitimate interest, by taking steps at your request to enter into such a contract.
  We may also use Customer Data to send you recommendations via email (or Facebook or other Social Media adverts or other display advertisements) about our goods and services that may be of interest to you. Our lawful ground for this processing is legitimate interest.
- User Data includes data about how you use our website or any other online services together with any data that you post for publication on our website on social media channels managed by us or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases and to enable

publication and administration of our website and other online services and business. Our lawful ground for this processing is legitimate interest.

Technical Data includes data about your use of our website and other online services such as your IP address, log-in data where relevant, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is legitimate interest.
Marketing Data includes data about your preferences in receiving marketing from us and your communication preferences.
We process this data to enable you to receive our email newsletters, to participate in promotions such as competitions and prize draws, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of any advertising. Our lawful ground for this processing is our legitimate interest, for consent to send you direct marketing via email, to study how customers use our products/services and to develop our products and services.

Sensitive Data

We do not collect any Sensitive Data about you. Sensitive data refers to data that 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 do not collect any information about criminal convictions and offences.

How We Collect Your Personal Data

At Cremoloso Gelato Ltd, we collect your personal data through various methods to ensure we provide you with the best possible service. Here’s how we may collect your information:

Direct Interactions:
- Forms: When you fill in forms on our website, such as signing up for our newsletter or registering as a wholesale customer.
- Emails and Messages: When you communicate with us via email, text messages, or WhatsApp.
Newsletter Sign-Up:
- When you sign up for the Cremoloso Gelato Ltd email newsletter through our website, we will collect the following information:
  - First name and surname
  - Email address
  - Postcode (when confirming your subscription)
- We will send you regular email updates, which will include the option to unsubscribe at any time. Unsubscribing will initially suppress your information in our email database so you will no longer receive email communications from us, and your data will be completely deleted after 90 days.
Wholesale Customers:
- If you register as a wholesale customer, either through a form emailed to you or via a partner website like Qwirl, we may collect the following information:
  - First name and surname
  - Email address
  - Company name (if applicable)
  - Company address (if applicable)
  - Telephone number
  - Other information relevant to wholesale purposes
Competitions, Surveys, and Offers:
- From time to time, we may carry out competitions, surveys, or offers and may ask for your contact details as part of this promotion. We may collect the following information:
  - First name and surname
  - Contact information including email address and telephone number
  - Demographic information such as postcode, any preferences, and interests
  - Other information relevant to customer surveys and/or offers
  - Entry into a competition or survey may also include the option to join the Cremoloso Gelato Ltd email newsletter, but entry will not be dependent on you joining the email list.
- We will keep all entrants’ contact details for 90 days after the competition, offer, or survey date has ended. After this time, your contact details will be deleted unless you have joined the Cremoloso Gelato Ltd email newsletter database, in which case your first name, surname, email address, and postcode will be retained. Winners’ details will be kept in full for up to 36 months.
Wholesale Customer Data Retention:
- If you are a Wholesale customer, your details will be retained for the duration of our business relationship and for a period of up to 7 years after the relationship has ended for tax, accounting, and legal purposes. This includes your business name, contact person, address, email, phone number, and transaction history.

Data Security and Your Rights

Data Security: We ensure that all data is securely stored and only accessible by authorized personnel.
Your Rights: You have the right to request access to your personal data, request corrections, or request deletion, subject to legal constraints. We will only use your personal data for the purpose for which it was collected, or for a reasonably compatible purpose if necessary. For more information on this, please email us at info@cremolosogelato.co.uk. In case we need to use your details for an unrelated new purpose, we will let you know and explain the legal grounds for processing.

Automatic Data Collection and Third Parties

Automatic Data Collection: We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see below for more details about this.
Third-Party Data: We may receive data from third parties such as analytics providers (e.g., Google based outside the EU), advertising networks (e.g., Facebook based outside the EU), search information providers (e.g., Google based outside the EU), and providers of technical, payment, and delivery services, such as data brokers or aggregators. We may also receive data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

Legal Compliance

Data Processing: We may process your personal data without your knowledge or consent where this is required or permitted by law.

Marketing Communications

You will receive marketing communications from us if you have opted in to Cremoloso Gelato Ltd newsletter or if you stock Cremoloso Gelato Ltd products, whether purchased directly from us or via a third party.
You can ask us to stop sending you marketing messages at any time by unsubscribing from our email newsletter.
If you opt out of receiving marketing communications, this opt-out does not apply to data provided as a result of other transactions, such as purchases.

Disclosures of your personal data

We may have to share your personal data with the parties set out below:
Service providers who provide IT services and system administration services.
Professional advisers including lawyers, bankers, auditors and insurers.
Government bodies that require us to report any processing activities.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

Data Security

Security measures are in place to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We only allow access to your personal data to the marketing team at Cremoloso Gelato Ltd. We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.
When deciding how long to keep data for, other than data supplied for competitions, surveys or offers, we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these processing purposes can be achieved by other means, and legal requirements.
For tax purposes the law requires us to keep basic information about our customers (including contact, identity, financial and transaction data) for seven years after their last transaction.

Your Legal Rights

Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights
If you wish to exercise any of the rights set out above, please email us at info@cremoloso.co.uk
You may request details of personal information which we hold about you under the Data Protection Act 1998. If you would like a copy of the information held on you please write to The Cremoloso Gelato Ltd, 349b Garratt Lane, London SW18 4DX. 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 will respond to all legitimate requests within 30 days. If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). If you do have a complaint, we would be grateful if you would contact us first, so that we can try to resolve it for you.

Cookies and how we use them

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 to better 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 and social media sites

Our website may contain links to other websites or social media sites of interest. However, once you have used these links to leave our site, you should note that 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 privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Contact Details

Elisa Peloni, Cremoloso Gelato Ltd
Email address: info@cremolosogelato.co.uk
Postal address: 349b Garratt Lane, London SW18 4DX.

If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.