ABOUT US, OUR TARGET AUDIENCE AND THIS PRIVACY NOTICE
This notice sets out how Sugarboat. processes your personal data if you are a customer or a user of Sugarboat’s website or mobile applications. Sugarboat’s services are neither aimed at nor intended for children. If you are a child, then you must inform your parent or guardian of this notice.

Sugarboat. is the trading name of Sugarboat Limited (collectively referred to as “Sugarboat”, “we”, “us” or “our” in this notice).  We are the data controller of your personal data.

Our data protection officer (DPO) is responsible for overseeing questions in relation to this notice.  If you have any questions about this notice, including any requests to exercise your legal rights, then please contact our DPO at hello@sugarboat.co.uk.

CHANGES TO THIS NOTICE AND YOUR PERSONAL DATA
We may update this notice from time to time and will notify you of changes where we are required to do so by law.

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. An easy way to do this is through your Sugarboat account, but please also feel free to contact us.

THE PERSONAL DATA WE COLLECT ABOUT YOU
Personal data means any information about an individual from which that person can be identified.  It does not include data where the identity has been removed (anonymous data).

We may collect, use, store, transfer and otherwise process different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products/services you have purchased from us.
  • Technical Data includes information collected when you access our website or mobile applications, your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website or mobile applications.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, mobile applications, Wi-Fi and similar electronic services.
  • Marketing and Communications Data includes your marketing and communication preferences.
  • CCTV Data includes footage from CCTV and other similar equipment which we operate in our stores.

FAILURE TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (e.g., to provide you with products/services).  In this case, we may have to cancel a product/service but we will notify you if this is the case at the time.

HOW WE COLLECT YOUR PERSONAL DATA
We use different methods to collect data from and about you including as set out below:

  • Direct interactions.You may give us your personal data in your direct interactions with us (e.g., Identity Data, Contact Data and Financial Data) by filling in forms, through our mobile applications or by corresponding with us by post, phone, email or otherwise.This includes personal data you provide when you: (i) enquire about, apply for or order our products/services; (ii) create an account; (iii) subscribe to our communications; (iv) request marketing to be sent to you; (v) enter a competition, promotion, raffle or survey; or (vi) give us feedback or contact us.
  • Website, mobile applications and cookies.  As you interact with our website and mobile applications, we will automatically collect Technical Data about your device, browsing actions and patterns.  We collect this personal data by using cookies, server logs and other similar technologies.  We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Notice for further details.
  • Technical Data from third party analytics providers, advertising networks and search information providers.
  • Contact Data, Financial Data and Transaction Data from providers of technical, payment and delivery services.

HOW WE PROCESS YOUR PERSONAL DATA
We will only process your personal data when the law allows us to do so.  Most commonly, we will process your personal data in the following circumstances:

  • Performance of a contract: Where we need to perform the contract we are about to enter into or have entered into with you.
  • Legitimate interests: Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Legal or regulatory obligation: Where we need to comply with a legal or regulatory obligation that we are subject to.
  • Consent: Where you have given us consent to process your personal data for a specific purpose.
  • With limited exceptions (e.g., some of our electronic marketing), we do not rely on consent as a lawful basis for processing your personal data.  You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES AND LAWFUL BASES FOR PROCESSING YOUR PERSONAL DATA
We have set out below a description of all the ways we plan to process your personal data, and which of the lawful bases we rely on to do so.  We have also identified what our legitimate interests are where appropriate.

Purpose/Activity: To register you as a new customer

  • Type of personal data:(a) Identity Data, (b) Contact Data
  • Lawful basis of processing: Performance of a contract

Purpose/Activity: To process and deliver your order (including managing payments, fees and charges, and collecting and recovering money owed to us)

  • Type of personal data:(a) Identity Data, (b) Contact Data, (c) Financial Data, (d) Transaction Data, (e) Marketing and Communications Data
  • Lawful basis of processing: (a) Performance of a contract, (b) Legitimate interests (to recover debts due to us)

Purpose/Activity: To manage our relationship with you (including notifying you about changes to our terms or this notice and asking you to leave a review or take a survey)

  • Type of personal data:(a) Identity Data, (b) Contact Data, (c) Profile Data, (d) Marketing and Communications Data
  • Lawful basis of processing: (a) Performance of a contract, (b) Legal or regulatory obligation, (c) Legitimate interests (to keep our records updated and understand how customers use our products/services)

Purpose/Activity: 
To enable you to take part in a prize draw, competition, raffle or complete a survey

  • Type of personal data:(a) Identity Data, (b) Contact Data, (c) Profile Data, (d) Usage Data, (e) Marketing and Communications Data
  • Lawful basis of processing: (a) Performance of a contract, (b) Legitimate interests (to understand how customers use our products/services, to develop them and grow our business)

Purpose/Activity: To administer and protect our business, website and mobile applications (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

  • Type of personal data:(a) Identity Data, (b) Contact Data, (c) Technical Data
  • Lawful basis of processing: (a) Legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise), (b) Legal obligation

Purpose/Activity: To deliver relevant content and advertisements to you and measure or understand the effectiveness our advertising

  • Type of personal data:(a) Identity Data, (b) Contact Data, (c) Profile Data, (d) Usage Data, (e) Marketing and Communications Data, (f) Technical Data
  • Lawful basis of processing: Legitimate interests (to understand how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

Purpose/Activity: To use data analytics to improve our website, mobile applications, products/services, marketing, customer relationships and experiences

  • Type of personal data:(a) Technical Data, (b) Usage Data
  • Lawful basis of processing: Legitimate interests (to define types of customers for our products/services, to keep our website and mobile applications updated and relevant, to develop our business and to inform our marketing strategy)

Purpose/Activity: To make suggestions and recommendations to you about products/services that may be of interest to you

  • Type of personal data:(a) Identity Data, (b) Contact Data, (c) Technical Data, (d) Usage Data, (e) Profile Data, (f) Marketing and Communications Data
  • Lawful basis of processing: Legitimate interests (to develop our products/services and grow our business)

Purpose/Activity: To keep our stores safe and secure

  • Type of personal data: CCTV Data
  • Lawful basis of processing: Legitimate interests (to keep our stores secure and those within them safe)

CHANGE OF PURPOSE
We will only process your personal data for the purposes that we collected it, unless we reasonably consider that any further processing is compatible with the original purpose.  If you would like an explanation as to how further processing is compatible with the original purpose, then please contact us.

If we need to process your personal data for an unrelated purpose, then we will notify you and we will explain the lawful basis which allows us to do so.

We may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

MARKETING AND EXERCISING YOUR RIGHT TO OPT-OUT OF MARKETING
You will receive marketing communications from us if you have requested information from us or purchased products/services from us and you have not opted out of receiving that marketing.

If you ask us to stop processing your personal data for marketing purposes (e.g., by following the opt-out links on any electronic marketing sent to you or by otherwise contacting us), then we will do so.

NO THIRD-PARTY MARKETING
We do not share your personal data with any third parties for their own marketing purposes.

COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.  If you disable or refuse cookies, then some parts of our website or mobile applications may become inaccessible or not function properly.  For more information about the cookies we use, please see our Cookie Notice.

DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes that we collected the personal data.

  • Service providers who provide IT and system administration services.
  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • HMRC, regulators and other authorities.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.  Alternatively, we may seek to acquire other businesses or merge with them.  If a change happens to our business, then the new owners may process your personal data in the same way as set out in this notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.  We do not allow our third-party service providers to process your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

INTERNATIONAL TRANSFERS
In some cases the parties who we use to process personal data on our behalf are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.  For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.  For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

If you would like further information on the specific mechanism used by us when transferring your personal data out of the EEA, then please contact us.

DATA SECURITY
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.

DATA RETENTION
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 and for the establishment or defence of legal claims.

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 requirements.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS AND HOW TO MAKE A COMPLAINT
Under certain circumstances, you have rights under data protection laws in relation to your personal data.  In summary these are the rights of accessrectification (i.e., correction), erasure (also known as the “right to be forgotten”), restrictionobjectiondata portability and withdrawal of consent.  If you wish to exercise any of these rights, then please contact us.

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.

You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority 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 feel free to contact us in the first instance.