Privacy & Cookies Policy
1. Introduction
We are committed to safeguarding the privacy of our website visitors, supplier partners ("Partners") and customers. In this policy we explain how we will handle your personal data.
This policy applies where we are acting as a data controller with respect to your personal data; in other words, where we determine the purposes and means of the processing of that personal data.
We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.
In this policy, "we", "us" and "our" refer to The Local Trove Limited. For more information about us, see Section 17.
2. The personal data that we collect, the source, the purpose of the processing, the legal basis of the processing and our retention periods.
In this Section 2 we have set out the general categories of personal data that we process.
| Type of Personal Data | Source of the Personal Data | Purpose of the Processing | Legal Basis of the Processing | Retention Policy |
| We may process "contact data". The contact data may include your name, email address, telephone number and postal address. | The source of the contact data is you and/or your employer. | Day to day operations of the business. Responding to your queries. Managing and delivering your orders. Keeping your data secure. Personalising our services so you only see products available in your delivery area. | Our legitimate business interests. | A minimum period of one year following the date of the most recent contact between you and us, and for a maximum period of six years following the end of any contractual relationship between us. |
| We may process your "account data". The account data may include your account identifier, name, email address, account creation and modification dates, website settings and marketing preferences. | The primary source of the account data is you although some elements of the account data may be generated by our website. | Day to day operations of the business and fulfilling your orders. Keeping you up to date with business developments. Keeping your data secure. | Our legitimate business interests and/ or your consent. | Account data will be retained for a period of six years following the date of closure of the relevant account; |
| We may process customer and Partner "relationship data". The relationship data may include your name, your contact details, your employer details and information contained in or relating to communications between us and you. | The source of the relationship data is you. | Day to day operation of the business. Keeping your data secure. | Our legitimate business interests. | Relationship data will be retained for a period of six years following the date of termination of the relevant customer relationship. |
| We may process "transaction data". The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details. | The source of the transaction data is you and/or our payment services provider. | Processing your orders and payments. Keeping your data secure. | Performing a contract between us. | Transaction data will be retained for a period of ten years following the date of the transaction. |
| We may process "communication data". The communication data may include the communication content and metadata associated with the communication. | The source of the communication data is you and our website. | Day to day business operations. Dealing with queries and complaints. | Our legitimate business interests. | Communication data will be retained for a minimum period of one year following the date of the communication in question, and for a maximum period of six years following that date. |
| We may process “usage data". The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. | The source of the usage data is our analytics tracking system. | Day to day business operations to improve our services. | Your consent to our analytics cookies and our legitimate business interests. | Usage data will be retained for up to six years following the date of collection. |
| (Note that we may retain your personal data where such retention is necessary for compliance with a legal obligation, or in order to protect your vital interests or the vital interests of someone else). |
3. Other general types of processing
Legal claims - We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
Legal compliance and vital interests - We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
4. Providing your personal data to others
We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
Your personal data held in our website database will be stored on the servers of our hosting services providers.
We may disclose your personal data to our website developers and support providers insofar as reasonably necessary for developing and supporting the smooth and problem free operation of our technology.
Financial transactions relating to our website and services are handled by our payment services providers, Stripe. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at https://stripe.com/gb/privacy.
In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. International transfers of your personal data
In this Section 5, we provide information about the circumstances in which your personal data may be transferred to a third country under UK data protection law.
Stripe (our payment processor) is situated in the USA. Stripe uses one or more of the following mechanisms: EU Standard Contractual Clauses with a data recipient outside the EEA or the UK, verification that the recipient has implemented Binding Corporate Rules, or verification that the recipient adheres to the EU-US and Swiss-US Privacy Shield Framework.
You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
6. Security of personal data
We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
We will store your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website).
7. Your rights
Your principal rights under data protection law are:
(a) the right to access - you can ask for copies of your personal data;
(b) the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure - you can ask us to erase your personal data;
(d) the right to restrict processing - you can ask us to restrict the processing of your personal data;
(e) the right to object to processing - you can object to the processing of your personal data;
(f) the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
(h) the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
8. Third party websites
Our website includes hyperlinks to, and details of, third party websites. In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.
9. Personal data of children
Our website and services are targeted at persons over the age of 18. If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
10. Updating information
Please let us know if the personal information that we hold about you needs to be corrected or updated.
11. About cookies
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
12. Cookies that we use
We use cookies for the following purposes:
(a) authentication and status - we use cookies to identify you when you visit our website and as you navigate our website, and to help us determine if you are logged into our website;
(b) shopping cart - we use cookies to maintain the state of your shopping cart as you navigate our website;
(c) personalisation - we use cookies to store information about your preferences and to personalise our website for you;
(d) security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;
(e) analysis - we use cookies to help us to analyse the use and performance of our website and services; and
(f) cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally.
13. Cookies used by our service providers
Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
We use Google Analytics. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google's use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google's privacy policy at https://policies.google.com/privacy.
We use a Facebook pixel on our website. Using the pixel, Facebook collects information about the users and use of our website. The information is used to personalise Facebook advertisements and to analyse the use of our website. To find out more about the Facebook pixel and about Facebook's use of personal data generally, see the Facebook cookie policy at https://www.facebook.com/policies/cookies/ and the Facebook privacy policy at https://www.facebook.com/about/privacy. The Facebook cookie policy includes information about controlling Facebook's use of cookies to show you advertisements. If you are a registered Facebook user, you can adjust how advertisements are targeted
14. Managing cookies
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647 (Chrome);
(b) https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop (Firefox);
(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and
(f) https://support.microsoft.com/en-gb/help/4468242/microsoft-edge-browsing-data-and-privacy (Edge).
Blocking all cookies will have a negative impact upon the usability of many websites. For example, if you block cookies, you will not be able to use all the features on our website.
15. Amendments
We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this policy. We will notify you of significant changes to this policy by email.
16. Our details
This website is owned and operated by The Local Trove Limited.
We are registered in England and Wales under registration number 12842553, and our registered office is at 4. Mount Ephraim Road, Tunbridge Wells, TN1 1EE.
You can contact us:
(a) using our website contact form;
(b) by telephone, on the contact number published on our website; or
(c) by email, to hello@thelocaltrove.com
17. Data protection registration
18.1 We are registered as a data controller with the UK Information Commissioner's Office.
18.2 Our data protection registration number is ZB169586
