Last updated: 24th May 2018.
This Policy provides you with the information required by the General Data Protection Regulation (GDPR), Regulation (EU) 2016/679 of the European Parliament and Council, on the protection of natural persons in relation to the processing of personal data. It explains why we collect and use personal information about people who visit and use our website and otherwise engage with us (“you”) and the types of people to whom we may disclose it. It also explains the lawful basis on which we do this, how long we keep it for and informs you of certain rights you have regarding your personal information under GDPR.
In this Policy we refer variously to “personal information”, “data” and “personal data” and similar expressions. We use these interchangeably to mean information capable of identifying you, which is personal data as defined in GDPR. We also sometimes refer to “processing” such data. This means any operation we perform on it, such as collecting, organising, storing, updating, using, disclosing and erasing it.
We may change this policy from time to time, so please check this page occasionally to ensure that you are aware of any changes.
Any questions regarding this Policy and our Privacy practices should be sent to our general enquiry email address at email@example.com.
Who we are?
We are Etefy Limited (“we”, “us”, “our” or “Etefy”), a company incorporated in England and Wales (company registration number 09643226), with our registered office at A03 Parkhall Business Centre, Martell Road, London, England, SE21 8EN.
We are the data controller when we process your personal information in connection with our business, for the purposes we have determined as set out below in this Policy.
Purposes - why do we collect and use your information
The purposes of our collecting and using personal information we may obtain from you or about you, primarily being customers and other users of our website, are as follows:
- to enable you to register on our website
- to enable customers to place orders
- to enable us to fulfil those orders
- to help us improve and develop our services and products
- to provide information about our services and products which may be of interest
- to communicate and maintain relationships with our customers and users
- for our internal administration
- to ensure network and information security
- to protect our legal rights and interests
- to enable a sale or other transaction relating to our business
How do we collect information?
We obtain information about our customers, through different methods, as described below.
When our customers register with us, we ask for personal information such as name, address, contact details, email and delivery address.
We may obtain information about you from third parties, for example those who provide services to us.
We may obtain information about you from our continuing relationship with you, information we gather from the technology on our website or which you use to access our services or products.
All relevant information is safely stored, and kept in our system, so that we can recognize you as a registered customer, and deliver products purchased through our platform. Further, we ask our customers for their credit or debit details, in order to process payments.
We also store any email correspondence you have sent us. This is so that we can keep record of any problems or concerns you may have had with our products or services.
We may record your call with our Customer Service Helpline, for monitoring and quality control of our services, or for training and development purposes.
What are the legal bases we rely on to collect and use your information?
The legal basis for our collection and use of your information depends on the purpose of the processing. This falls into the following categories:
- Contract - we need to process your personal data to comply with our contractual obligations, for example to deliver products you have ordered, or to take steps to enter into a contract at your request, for example to accept your registration as a customer.
- Legitimate Interests - we process your information where it is in our legitimate interests do so as an on-line grocery business and without prejudicing your interest or fundamental rights and freedoms.
- Legal Obligations - in particular circumstances we may need to process your information if the law requires us to, for example laws relating to fraud.
- Consent - In certain specific situations, we may collect and process your data with your specific freely given consent. For example, when you tick a box to receive email newsletters. When processing your personal data based on your consent, we'll always make clear to you which data is necessary in connection with a particular service and the purpose of the processing. You can withdraw that consent at any time, by unsubscribing.
How do you unsubscribe?
You may choose to unsubscribe from our marketing communications, when you sign up with us, or at any other time thereafter by emailing us at firstname.lastname@example.org.
Recipients - to whom do we provide, or give access to, your information?
We may disclose your personal information to:
- other businesses with the Etefy group
- third parties service providers, agents, subcontractors and other associated organisations who will help process your order or who we otherwise use to provide products or services or to operate our business, including our website operator and payment or payments cards service providers
- where required for a proposed sale or other transaction relating to our business.
Transferring your information outside of the EU
Your information may be transferred to countries outside the European Union ("EU"). For example, if any of our servers or our service providers are from time to time located in a non-EU country. These countries may not have data protection laws providing you with the same safeguards as GDPR.
If we transfer your information outside of the EU in this way, we will take steps to ensure that appropriate measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy. In particular, except where necessary to perform a contract with you or to perform or conclude a contract with a third party in your interest, we will ensure at least on the following safeguards is implemented:
- we will only transfer the data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
- where we transfer the data to third parties, we will use specific contracts between us and the recipient in a form approved by the European Commission; or
- where the transfer is to the USA, the recipient is within the EU-US Privacy Shield.
How long do we keep your data for?
We create records that contain your information. We manage these records to help us to serve you and for operational reasons. We normally keep your records for as long as you remain registered as a customer and for up to six years after your relationship with us ends.
What are your Privacy Rights?
You have the following rights in relation to your personal information:
- to be informed about how your personal information is being used by us
- to access the personal information we hold about you, and request its correction if necessary
- to request that we delete your data, or stop or restrict processing it
- to have your information "ported" to another service provider
- where we rely on your specific consent, to withdraw that consent without affecting the lawfulness of pervious processing based on it
- to stop receiving marketing messages (by unsubscribing as described above), and
- to complain to the Information Commissioner's Office, which is our supervisory authority for data protection matters - see ico.org.uk
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.
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 other websites 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.
The table below lists the cookies we collect and what information they store.
|FORM_KEY||Stores randomly generated key used to prevent forged requests.|
|PHPSESSID||Your session ID on the server.|
|GUEST-VIEW||Allows guests to view and edit their orders.|
|PERSISTENT_SHOPPING_CART||A link to information about your cart and viewing history, if you have asked for this.|
|STF||Information on products you have emailed to friends.|
|STORE||The store view or language you have selected.|
|MAGE-CACHE-SESSID||Facilitates caching of content on the browser to make pages load faster.|
|MAGE-CACHE-STORAGE||Facilitates caching of content on the browser to make pages load faster.|
|MAGE-CACHE-STORAGE-SECTION-INVALIDATION||Facilitates caching of content on the browser to make pages load faster.|
|MAGE-CACHE-TIMEOUT||Facilitates caching of content on the browser to make pages load faster.|
|SECTION-DATA-IDS||Facilitates caching of content on the browser to make pages load faster.|
|PRIVATE_CONTENT_VERSION||Facilitates caching of content on the browser to make pages load faster.|
|X-MAGENTO-VARY||Facilitates caching of content on the server to make pages load faster.|
|MAGE-TRANSLATION-FILE-VERSION||Facilitates translation of content to other languages.|
|MAGE-TRANSLATION-STORAGE||Facilitates translation of content to other languages.|
|NEAREST-DEPOT||Facilitates one hour delivery.|
|ZIP_CODE||Facilitates one hour delivery.|