Variety Brands Ltd (“we“, “us“, “our“) understands that protecting your personal information is important. This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or collected by us, when interacting with you.

This Privacy Policy takes into account the requirements of the General Data Protection Regulation (EU 2016/679) (UK GDPR) and the Data Protection Act 2018 (DPA 2018) (together, the GDPR).

Table of contents

1. Information we collect
2. How we collect personal information
3. Why we collect, hold, use and disclose personal information
4. Purposes and legal bases for processing personal information
5. Our disclosures of personal information to third parties
6. Overseas disclosure and data transfers
7. Data retention
8. Your rights and controlling your personal information
9. Storage and security
10. User-generated content
11. Cookies and analytics
12. Links to other websites
13. Amendments

Information we collect

Personal information is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable.

The types of personal information we may collect about you include:

• Identity data including your name, age and profession.
• Contact data including your telephone number, address and email.
• Financial data including bank account and payment card details (through our industry certified third party payment processor).
• Transaction data including details about payments to you from us and from you to us and other details of products and services you have purchased from us or we have purchased from you.
• Technical and usage data when you access any of our websites or platforms, details about your internet protocol (IP) address, login data, browser session and geo-location data, statistics on page views and sessions, device and network information, acquisition sources, search queries and/or browsing behaviour, access and use of our website (including through the use of Internet cookies), and communications with our website.
• Profile data including your username and password for Variety Brands and any other website, platform or mobile application we operate, profile picture, purchases or orders you have made with us, content you post, send, receive and share through our platform, information you shared with our social media platforms, and support requests you have made.
• Interaction data including information you provide to us when you participate in any interactive features, including surveys, contests, promotions, activities or events.
• Marketing and communications data including your preferences in receiving marketing from us and our third parties and your communication preferences.
• Professional data including where you are a worker of ours or applying for a role with us, your professional history such as your previous positions and professional experience, or whether you hold required authorisations or licenses.
• Sensitive information is a sub-set of personal information that is given a higher level of protection. Sensitive information means information relating to our racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information. We do not actively request sensitive information about you. If at any time we need to collect sensitive information about you, unless otherwise permitted by law, we will first obtain your consent and we will only use it as required or authorised by law.

How we collect personal information

We collect personal information in a variety of ways, including:

• when you provide it directly to us, including face-to-face, over the phone, over email, or online;
• when you use our websites, platforms or mobile applications;
• when you complete a form, such as registering for any events or newsletters, or responding to surveys;
• when you use any website we operate (including from any analytic and cookie providers or marketing providers. See the “Cookies” section below form more detail on the use of cookies);
• from third parties directly or indirectly related to the normal use of our website, platform or mobile applications;
• from publicly available sources.

Why we collect, hold, use and disclose personal information

We collect, hold, use and disclose your personal information for a variety of purposes, including:

• to enable you to access our website, platform or mobile applications, including to provide you with a login (identity data, contact data);
• to contact you and communicate with you about our business, including in response to any support requests you lodge with us or other enquiries you make with us (identity data, contact data, profile data);
• to contact and communicate with you about any enquiries you make with us via any website, platform or mobile application we operate (identity data, contact data);
• for internal record keeping, administrative, invoicing and billing purposes (identity data, contact data, financial data, transaction data);
• for analytics, market research and business development, including to operate and improve our business, associated applications and associated social media platforms (profile data, technical and usage data);
• for advertising and marketing, including to send you promotional information about our events and experiences and information that we consider may be of interest to you (identity data, contact data, technical and usage data, profile data, marketing and communications data);
• to run promotions, competitions and/or offer additional benefits to you (identity data, contact data, profile data, interaction data, marketing and communications data);
• if you have applied for employment with us, to consider your employment application (identity data, contact data, professional data);
• to comply with our legal obligations or if otherwise required or authorised by law (any relevant personal information).

Purposes and legal bases for processing personal information

We collect and process personal information about you only where we have legal bases for doing so under applicable laws, including:

• to enable you to access our website, platform or mobile applications, including to provide you with a login (performance of a contract with you);
• to contact you and communicate with you about our business, including in response to any support requests you lodge with us or other enquiries you make with us (performance of a contract with you);
• to contact and communicate with you about any enquiries you make with us via any website, platform or mobile application we operate (legitimate interests: to ensure we provide the best client experience we can offer by answering all of your questions);
• for internal record keeping, administrative, invoicing and billing purposes (performance of a contract with you; to comply with legal obligations; legitimate interests: to recover debts due to use and ensure we can notify you about changes to our terms of use and any other administrative points);
• for analytics, market research and business development, including to operate and improve our business, associated applications and associated social media platforms (legitimate interests: to keep our website updated and relevant, to develop our business, improve our business and to inform our marketing strategy);
• for advertising and marketing, including to send you promotional information about our events and experiences and information that we consider may be of interest to you (legitimate interests: to develop and grow our business);
• to run promotions, competitions and/or offer additional benefits to you (legitimate interests: to facilitate engagement with our business and grow our business);
• if you have applied for employment with us, to consider your employment application (legitimate interests: to consider your employment application);
• to comply with our legal obligations or if otherwise required or authorised by law (to comply with any legal obligations).

If you have consented to our use of data about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your data because we or a third party have a legitimate interest to do so, you have the right to object to that use though, income cases, in some cases, this may mean no longer doing business with us. Further information about your rights is available below.

Our disclosures of personal information to third parties

We may disclose personal information to:

• our employees, contractors and/or related entities;
• artificial intelligence providers, IT service providers, data storage, web-hosting and server providers;
• marketing or advertising providers;
• professional advisors, banks, auditors, our insurers and insurance brokers;
• payment systems or operators or processors;
• our existing or potential agents or business partners;
• sponsors or promotors of any promotions or competitions we run;
• if we merge with, or are acquired by, another company, or sell all or a portion of our assets, your personal information may be disclosed to our advisers and any prospective purchaser’s advisers and may be among the assets transferred;
• courts, tribunals and regulatory authorities, in the event you fail to pay for goods of services we have provided to you;
• courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
• third parties to collect and process data, such as analytic providers and cookies; and
• any other third parties as required or permitted by law, such as where we receive a subpoena.

Overseas disclosure and data transfers

We primarily store your personal information in the United Kingdom and as such is protect by local privacy regulations. However, there may be times where we need to transfer your personal information outside of the United Kingdom, and in such cases, we will perform those transfers using appropriate safeguards in accordance with the requirements of applicable data protection laws and we will protect the transferred personal information in accordance with this Privacy Policy. This includes only transferring your personal information to countries that have been deemed by applicable data protection laws to provide an adequate level of protection for personal information or including standard contractual clauses in our agreements with third parties that are overseas.

Where we disclose your personal information to third parties, those third parties may store, transfer or access personal information outside of the United Kingdom in jurisdictions, such as the United States, which may or may not have equivalent privacy regulations.

Data retention

We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collect it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information 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.

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Your rights and controlling your personal information

Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to work with you as a customer or supplier of our business.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Restrict and unsubscribe: To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out facilities provided in the communication.

Access: You may request access to the personal information that we hold about you. Please note, in some situations, we may be legally permitted to withhold access to your personal information. If we cannot provide access to your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal. If we can provide access to your information in another form that still meets your needs, then we will take reasonable steps to give you such access.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information. If we cannot correct your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal.

Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. If you are not satisfied without our response, you may contact the Information Commissioner’s Office (if you are a United Kingdom resident).

Extra rights for EU and UK individuals

You may request details of the personal information that we hold about you and how we process it (commonly known as a “data subject request”). You may also have a right in accordance with applicable data protection law to have your personal information rectified or deleted, to restrict our processing of that information, to object to decisions being made based on automated processing where the decision will provide legal effect or a similarly significant effect on you, to stop unauthorised transfers of your personal information to a third party and, in some circumstances, to have personal information relating to your transferred to you or another organisation.

If you are not happy with how we are processing your personal information, you have the right to make a complaint at any time to the relevant Data Protection Authority based on where you live. We would, however, appreciate the chance to deal with your concerns before you approach the Data Protection Authority, so please contact us in first instance using the details set out in this Privacy Policy.

For any questions or notices, please contact us at: support@varietybrands.co.uk

Storage and security

We are committed to ensuring that the personal information we collect 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 personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.

User-generated content

We may enable you to post reviews, comments, photos and other user-generated content. Any content you choose to submit will be accessible by anyone, including third parties not associated with us. We have no control over how others may use or misuse information you make publicly available. We are not responsible for the privacy, security or accuracy of any user-generated content you choose to post or for the use or misuse of that information by any third parties.

Cookies and analytics

We may use cookies on our website from time to time. Cookies are text files placed in your computer’s browser to store your preferences, Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do recognise you when you return to our online website and allow third parties to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online website with personal information., this information may be linked to the data stored in the cookie.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

Cloudflare Analytics: We may use tools provided by Cloudflare that allows us to measure performance data and log technical information such as your device type, page views, operating system and IP address. Fore more information, please see Cloudflare’s Privacy Policy here.

For more information about the cookies we use. please see our Cookie Policy.

Links to other websites

Our website may contain links to other party’s websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

Amendments

We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website. We recommend you check our website regularly to ensure you are aware of our current Privacy Policy.

For any questions or notices, please contact our Privacy Officer at: support@varietybrands.co.uk