Log data
Even if you do not log in or register on our website, but simply browse our website, data is collected and stored and processed by us. Specifically, this requires the IP address of your computer, Date and time of access, Name and URL of the accessed file, Browser used, Number of bytes transferred, Status of the page retrieval, Session ID, Referrer URL.

Hosting
We use the website platform Bluehost a company owned by Newfold Digital, to host and display the website on the basis of processing on our behalf. All data collected on our website is processed on the servers of Bluehost. The legal basis for data processing is our legitimate interest in providing an appealing website.

Cookies
We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. There are different types of cookies: a) Essential Cookies. Essential cookies are cookies to provide a correct and user-friendly website; and b) Non-essential Cookies. Non-essential Cookies are any cookies that do not fall within the definition of essential cookies, such as cookies used to analyse your behaviour on a website (“analytical” cookies) or cookies used to display advertisements to you (“advertising” cookies).

As set out in the UK’s Privacy and Electronic Communications Regulations (“PECR”) and the EU`s Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of Non-essential Cookies. For further information on the cookies we use, please refer to our Cookie Policy. The legal basis for processing is our legitimate interest and your consent.

Cookie consent
Our website uses a cookie consent tool, to obtain your consent to the storage of cookies and to document this consent. When you enter our website, the following Personal Data is transferred to us: i) Your consent(s) or revocation of your consent(s); ii) Your IP address; iii) Information about your browser; iv) Information about your device; v) Time of your visit to our website. The basis for processing is our legitimate interest and your consent.

Google Fonts
We integrate the fonts of the provider Google LLC, whereby the user’s data is used solely for the purpose of displaying the fonts in the user’s browser. The integration is based on my legitimate interest in a technically secure, maintenance-free and efficient use of fonts, their uniform display and taking into account possible licensing restrictions for their integration. The legal basis for this processing is our legitimate interest.

Font Awesome
We integrate Font Awesome of Fonticons Inc, whereby the user’s data is used solely for the purpose of displaying the fonts in the user’s browser. The integration is based on our legitimate interest.

Links to other websites
Please note that if you use a link from our website to a third-party website, that third-party may also set new cookies that are not covered by this policy. In such cases, we recommend that you read the cookie policy on the third-party website itself.

Data we collect directly

Contacting us
If you contact us, we store and process the following data from you: Name, e-mail address, telephone number as well as other personal data that you provide when contacting us. This data is collected and processed exclusively for the purpose of contacting you and processing your request and then deleted, provided there is no legal obligation to retain it. The legal bases for processing are contract and our legitimate interest.

We are present on social media (currently Facebook, Instagram, TikTok and LinkedIn) and if you contact or connect with us via social media websites, we and the relevant social media website are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The legal basis is our legitimate interest, your consent or, in some cases, the initiation of a contract.

When using our services
The protection of your Personal Data is particularly important to us in the performance of our services. We therefore only want to process as much Personal Data (for example, your name, address, e-mail address or telephone number) as is absolutely necessary. Nevertheless, we rely on the processing of certain Personal Data, to fulfil our contractual obligations to you or to carry out pre-contractual measures and in the context of administrative tasks as well as organisation of our business, and compliance with legal obligations, such as archiving.

When buying one of our Investor Packs
To make a purchase, you may need to provide a valid payment method (e.g., credit card). Your payment information will be collected and processed by our authorised payment vendor Stripe Inc. We do not directly collect or store credit or debit card numbers ourselves in the ordinary course of processing transactions. The legal basis for the provision of a payment system is the establishment and implementation of the contract.

Administration, financial accounting, office organisation, contact management
We process data in the context of administrative tasks as well as organisation of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.

Marketing
Insofar as you have given us your separate consent to process your data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.

You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission to send you marketing information, or sometimes your consent is implied from your interactions or contractual relationship with us. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving a marketing communication based on your interactions or contractual relationship with us.

Direct Marketing generally takes the form of email using Groove Digital’s groovemail but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent or made by us or on our behalf will include a means by which you may unsubscribe or opt out.

Principles of processing Personal Data

Storage and Retention
As far as necessary, we process and store your personal data for the duration of our business relationship, which also includes, for example, the initiation and execution of a contract.

In addition, we are subject to various storage and documentation obligations, which result from the minimum statutory retention periods in accordance with Companies House and HMRC, among others. The retention and documentation periods specified there are two to six years.

Security
Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us. We have also implemented numerous security measures (“technical and organisational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through our website.

Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.

Special Category Data
Unless specifically required when using our services and explicit consent is obtained for that service, we do not process special category data.

Automated decision-making
Automated decision-making is the process of making a decision by automated means without any human involvement. Automated decision-making including profiling does not take place.

Do Not Sell
We do not sell your Personal Data.

Sharing and Disclosure
We will not disclose or otherwise distribute your Personal Data to third parties unless this is a) necessary for the performance of our services including our shipping forwarder and, b) you have consented to the disclosure, c) or if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or other legal proceedings; or proceedings at home or abroad or to fulfil our legitimate interests.

International Transfer
We may transfer your Personal Data to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organisational measures to protect the Personal Data we transfer.