Summary of how we use your data
Spoon Guru is committed to protecting and respecting your privacy.
We use your personal data to fulfil our obligations under a contract, to provide you with the relevant Spoon Guru services, and to comply with our legal obligations.
Data is sometimes shared with trusted third parties within the EEA, where we subcontract some part of our service.
Where we rely on your consent, such as for subscription to our mail-list and marketing emails, you can withdraw this consent at any time.
What does this policy cover?
This website is not intended for children and we do not knowingly collect data relating to children.
It also describes your data protection rights, including a right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in the “What rights do I have?” section.
Please read this policy carefully to understand our views and practices regarding your personal data and how we will treat it.
INFORMATION WE MAY COLLECT FROM YOU
Information you give us.
You may give us information about you by: registering, filling out forms on our site, or corresponding with us by email.
This may include information you provide to us for: registering to use our site, subscribing to our mail-list, entering a competition, promotion or survey, or providing feedback.
The information you give us may include: your name, address, e-mail address, financial and credit card information, personal description and photograph.
Information we collect about you.
Information we receive from other sources.
We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties and may receive information about you from them. In particular: we may gather aggregated information about our users from analytics providers in order to gain insights about the effectiveness of our services.
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). Nor do we collect any information about criminal convictions and offences.
USES MADE OF THE INFORMATION & THE LEGAL BASIS FOR THIS USE
We will only use your personal data when the law allows us to.
We use information held about you in the following ways:
To fulfil a contract, or take steps linked to a contract (including when you make a request for services or purchase from us, or enter a competition we run):
for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to allow you to participate in interactive features of our service, when you choose to do so.
As required by us to conduct our business and pursue our legitimate interests, in particular:
to notify you about changes to our service;
to request feedback about our service;
to administer our site and to ensure that content from our site is presented in the most effective manner for you and for your computer;
as part of our efforts to keep our site safe and secure;
to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you (if applicable);
to improve our site to ensure that content is presented in the most effective manner for you and for your computer.
Where you give us consent:
to provide you with information about other goods and services we offer that are similar to those that you are using, have already purchased or enquired about;
to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by email or any notifications that you consent to, with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or
to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data (the registration form);
to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them;
For purposes which are required by law:
where we need parental consent to provide online services to children under 16. However, most of our websites and services are not designed for children under 16;
in response to requests by government or law enforcement authorities conducting an investigation.
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.
WHO WILL WE SHARE THIS DATA WITH, WHERE AND WHEN?
We may share your information with selected third parties including:
Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 5,000 cake searches were made by vegan profiles). We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience.
Analytics and search engine providers that assist us in the improvement and optimisation of our site.
We may disclose your personal information to third parties:
In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets, for due diligence purposes.
If Spoon Guru Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
In the event that the business is sold or integrated with another business or subject to material new investment, your details may be disclosed to our advisers and any prospective purchaser’s or investor’s adviser and will be passed to any new owners of the business.
WHERE WE STORE YOUR PERSONAL DATA
The majority of personal data that we collect is processed within the UK. Some data may be transferred to, and stored at, a destination within the European Economic Area (“EEA”). Particularly: our secure servers, which contain our users’ profile data, are based in the Republic of Ireland.
Information may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. If information were to be transferred outside of the EEA, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by EU Commission approved standard contractual clauses or a vendor’s Processor Binding Corporate Rules. A copy of the relevant mechanism can be provided for your review on request to email@example.com.
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.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
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 our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. If there is a cybersecurity breach, we have reporting procedures in place to notify the relevant parties, including the Information Commissioner’s Office and you, the data subject.
WHAT RIGHTS DO I HAVE?
Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests.
You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. We will usually inform you (before collecting your data) if we intend to use your data for such purposes. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at firstname.lastname@example.org.
You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine-readable format, and to ask us to share (port) this data to another controller.
In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet contractual or other legal requirements, or where we are using the data for direct marketing).
These rights may be limited, for example, if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.
To exercise any of these rights, you can get in touch with us using the details set out below. If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred.
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 could refuse to comply with your request in these circumstances.
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 try to respond to all legitimate requests within one month. Occasionally it could 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.
HOW LONG WILL YOU RETAIN MY DATA?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, 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 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.
Where we process registration data, we do this for as long as you are an active user of our sites and for 30 days after this.
Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data so that we can respect your request in future.
Where we process personal data for a survey or competition, we keep the data for six years from your last interaction with us.
Where we process personal data that you voluntarily provided to us, for example for feedback purposes, we will keep this data for as long as you continue to interact with us and for six months after this. After that, we may keep the information in an aggregated or anonymised format, but not in a way that you can be identified.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.