PRIVACY AND COOKIES POLICY
Essor Limited ("We", "Us") is committed to protecting and respecting your privacy. This Privacy and Cookies Policy ("Policy") (together with and any other documents referred to therein) sets out the basis on which the personal data collected from you, or that you provide to Us will be processed by Us. Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it.
For the purpose of the General Data Protection Regulation ("GDPR", from the GDPR implementation date) or, until GDPR implementation date, the Data Protection Act 1998, (collectively the "Data Protection Laws") the Data Controller is Essor Ltd (also trading as Secret Food Tours, Big Easy Food Tours, The Shoreditch Pub Crawl, Paris Bar Crawl).
YOUR PERSONAL INFORMATION
Information we collect from you
We collect and process some or all of the following types of information from you in the course of your use of the website or providing our services:
Information that you provide by filling in forms on the website, via e-mail or phone. This includes information provided at the time of purchasing services and/or goods, subscribing to updates, or requesting further information or services. We may also ask you for information when you report a problem with the website.
Specifically, personal details such as name, email address, phone number, dietary requirements, IP addresses or any information input by when using the website, completing our survey forms, using our Services.
In respect of the personnel engaged by our suppliers and resellers (or prospective suppliers and resellers), and with whom we come into contact in connection with the relationship between Us and our reseller and supplier, we will process your contact details such as your name, e-mail address, phone number, place of work and any other information that you provide to us.
If you contact Us, We may keep a record of that correspondence.
We may also ask you to complete surveys that We use for research purposes, although you do not have to respond to them.]
Details of your visits to the website including, but not limited to, IP address, traffic data, location data, weblogs and other communication data, and the resources that you access. When using our online form to book and purchase our products your name, e-mail address and phone number are required from you to enable Us to process your order. If you book and purchase our products over the phone your name, e-mail address are required from you to enable Us to process your order. Your name and email address is required from you to enable Us to add you to our mailing list. We will inform you at the point of collecting information from you, whether you are required to provide the information to Us.
USES MADE OF YOUR INFORMATION
We use information held about you in accordance with the following "legal bases" and for the following purposes:
To provide you with our website and to carry out any other obligations arising from any contracts entered into between you and Us. We rely on "performance of a contract with you" as the legal basis for this processing.
To notify you about changes to our services or contact you in the case of issues or emergencies in respect of the tour you have purchased. We rely on "performance of a contract with you" as the legal basis for this processing.
If you are engaged by one of our resellers or suppliers, we may process your data in order to perform our obligations pursuant to a contract with that customer or reseller. Where we do so we rely on "legitimate interest" and the legitimate interest is "carrying out a contract with a reseller or supplier".
To provide you with our newsletters. We rely on "consent" as the legal basis for this processing.
We rely on your consent as the lawful basis where you have agreed to participate in a survey, and for the processing of such personal information as has been collected through that survey.
To respond to your enquiries. Where you have contacted us via e-mail or telephone we rely on "legitimate interest" and the legitimate interest is "responding and contacting you regarding the enquiries you have made in relation to the services we offer".
To ensure that content on the website is presented in the most effective manner for you and for the device(s) you use to access and view the website. We rely on "legitimate interest" as the legal basis for this processing, and the legitimate interest is the maintenance and improvement of our website for the benefit of all our users.
To notify you that you have no completed your purchase. Automatic email if they haven't booked, discount code.
To allow you to participate in interactive features of our service, when you choose to do so.
We may use information held about you to promote our products and services that may be of interest to you. We will only do this where we reasonably believe that our services may be of interest to you and we rely on "legitimate interest" to promote our products and services to you. This may include instances where you follow us on social media, "like" or "comment" on any of our social media posts, we may use your details to respond back to you with an offer and/or promotional code.
If you do not want Us to use your data in this way please either (i) tick the relevant box situated on the form on which We collect your data (for example, the online purchase form); (ii) unsubscribe from our electronic communications using the method indicated in the relevant communication; or (iii) inform Us at any time by contacting Us at the contact details set out below.
DISCLOSURE OF YOUR INFORMATION
We routinely disclose your personal data to our third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (e.g. to host our servers).
If you purchase our products via our website payment is handled separately and securely through Ticketing Hub ("Payment Processor"). Your payment card details are never collected by Us. If you want to find out more about how the Payment Processor processes your personal data, you can refer to their own privacy notice.
We may also disclose your personal data 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; or
if We or substantially all of our assets are acquired by a third party, in which case personal data held by Us about our customers will be one of the transferred assets; or
if We are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions; or
to protect Our rights, property, or safety or that of our affiliated entities and our users and any third party We interact with the to provide the website; or
in relation to selected third parties only, only to the extent that you have consented to such selected third parties notifying you about certain goods or services, which may be if interest to you.
Other than as set out above, and save insofar as is necessary in order for Us to carry out our obligations arising from any contracts entered into between you and Us, We will not share your data with third parties unless We have procured your express consent to do so.
STORING YOUR PERSONAL DATA
We take appropriate measures to ensure that any personal data are kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where We are legally required to do so.
Keeping your personal data up to date
If your personal details change you may update them by contacting Us using the contact details below. If you have any questions about how We use data collected which relates to you, please contact Us by sending a request by email to the contact details below.
We will endeavour to update your personal data within seven (7) working days of any new or updated personal data being provided to Us, in order to ensure that the personal data We hold about you is as accurate and up to date as possible.
How long we keep your personal data
We will hold details relating to any purchase you make, such as your name, e-mail address, IP address for 20 years from the date of the transaction.
In instances where you have not completed a transaction We will hold your contact details for 20 years your details were inputted in this respect.
If you are engaged by one of our resellers or suppliers, we will hold your contact details for the period that supplier or reseller is registered with us and for 20 years after.
Where you have contacted us via e-mail and telephone, We will hold your contact and enquiry details for 20 years.
Where you have participated in our surveys, We will hold your survey details for 20 years.
Where we store your personal data
All information We hold about you is stored on secure servers.
The data that We collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). We will take all steps reasonably necessary to ensure that your data is held securely and in accordance with this Policy. Countries outside the EEA do not have the same data protection laws as the United Kingdom and EEA and we have therefore ensured that any of our suppliers who may transfer your personal data outside the EEA has put in place appropriate measures to protect your data, either by being a member of the US-EU Privacy Shield, or by entering into a European Commission approved contract (as permitted under Article 46(5) of the General Data Protection Regulation).
We will not otherwise transfer your personal data outside the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries. If you would like further information please contact Us (see 'Contact' below).
Under the General Data Protection Regulation you have a number of important rights free of charge.
In summary, those include rights to:
access to your personal data and to certain other supplementary information that this Policy is already designed to address
require Us to correct any mistakes in your information which We hold
require the erasure of personal data concerning you in certain situations
receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
object at any time to processing of personal data concerning you for direct marketing
object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
object in certain other situations to our continued processing of your personal data
otherwise restrict our processing of your personal data in certain circumstances
claim compensation for damages caused by our breach of any data protection laws.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner's Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
email at [email protected]
let Us have enough information to identify you (name, e-mail address and booking number),
let Us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
let Us know the information to which your request relates.
HOW TO COMPLAIN
We hope that We can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
We may collect information about your mobile phone, computer or other device from which you access the Website including where available your IP address, operating system and browser type, for systems administration and to report aggregate information to third parties affiliates. This is statistical data about our users' browsing actions and patterns, and does not identify any individual. We may, however, use such information in conjunction with the data We have about you in order to track your usage of our services.
The cookies We use include:
"Analytical" cookies. They allow Us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps Us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
"Strictly necessary" cookies. These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website, use a shopping cart or make use of e-billing services.
"Functionality" cookies. These are used to recognise you when you return to our Website. This enables Us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
"Targeting" cookies. These cookies record your visit to our Website, the pages you have visited and the links you have followed to our affiliates websites. We will use this information to make our Website, offers e-mailed to you and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
All questions, comments and requests regarding this Privacy and Cookies Policy should be addressed to [email protected] write to Us at Essor Ltd, 6-8 Bonhill St, London EC2A 4BX, UK