Data Privacy
The Sybarite Privacy Policy
We respect your privacy and are committed to protecting your personal data. Please read this Privacy Policy (Policy) carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities should you need to.
We collect, use and are responsible for certain personal data about you.
This Policy aims to provide you with information on how we collect and process your personal data through this website, when we interact with you or otherwise throughout the course of our dealings with you.
Who we are
This Website is operated by Chesamel Group Limited, trading as The Sybarite, with company number 08487694 and registered office at Pound House, 62a Highgate High Street, London, England, N6 5HX (referred to as “we”, “us” or “our” in this Policy). We are the controller responsible for your personal data. Chesamel is the company responsible for this website.
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below (see ‘How to contact us’ below).
Personal data we collect about you
Personal data, or personal information, 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). A data subject is the individual who the personal data relates to.
We may collect and use the following kinds of personal data about you (some of which is subject to you choosing to provide us with it):
Identity Data including your first name, last name, marital status, title, date of birth.
Contact Data including your address, email address and mobile phone number.
Technical Data including 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 this website.
Usage Data including information about how you use our website, products and services, click movements, browsing time and details.
Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.
We collect and use this personal data to provide services to you. If you do not provide personal data we ask for, it may delay or prevent us from providing such services to you.
This website is not intended for children and we do not knowingly collect data relating to children.
How your personal data is collected
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity and Contact Data by filling in forms, submitting or uploading information to our website, or by corresponding with us through our website, by phone, email or otherwise. This includes personal data you provide when you.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy [add link] for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
sanctions screening providers;
credit reference agencies;
customer due diligence providers
analytics provider, such as Google
through automated monitoring of our websites and other technical systems, such as our computer networks and connections, access control systems, communications systems, email and instant messaging systems.
How and why we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
to comply with our legal and regulatory obligations;
to provide you with services requested by you;
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; or
where you have given consent.
The table below explains what we use your personal data for and why.
What we use your personal data for
Our reasons
Providing our services to you
To perform our contract with you or to take steps at your request before entering into a contract
Preventing and detecting fraud against you or us
For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for you and/or us
Conducting checks to identify our customers and verify their identity.
Screening for financial and other sanctions or embargoes
Other activities necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety law or rules issued by our professional regulator
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, i.e. to minimise fraud and to prevent consumers registering more than one account in order to exploit our services.
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies
To comply with our legal and regulatory obligations
Management of your account with us
To perform our services for you
Customer service
To effectively perform our services
For our legitimate interests i.e. to make sure we can deliver the best service to you and respond to you when you need us
Asking for your feedback on our website and services
To effectively perform our services
For our legitimate interests or those of a third party, i.e. to be as effective as we can in delivering the best service to you at the best price
Ensuring business policies are adhered to, e.g. policies covering security and internet use
For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control
For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price
Ensuring the confidentiality of commercially sensitive information
For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information
To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures
For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
For our legitimate interests i.e. to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy
Preventing unauthorised access and modifications to systems
For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for you and/or us
To comply with our legal and regulatory obligations
Updating and enhancing customer records and our service provided to you
To perform our services
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products
Marketing our services and those of selected third parties to:
—existing and former customers;
—third parties who have previously expressed an interest in our services;
—third parties with whom we have had no previous dealings.
For our legitimate interests or those of a third party, i.e. to promote our business and services to existing and former customers
In certain circumstances where you have given your consent
Special Category Personal Data
Special category personal data includes personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership; genetic and biometric data (when processed to uniquely identify an individual); and data concerning health, sex life or sexual orientation.
Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws, for example only where:
we have your explicit consent;
the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or
the processing is necessary to establish, exercise or defend legal claims.
Marketing
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
We may use your personal data to send you updates (by email, text message, telephone or post) about our products and services, including exclusive offers, promotions or new products and services.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by:
[contacting us at the details below;
using the ‘unsubscribe’ link in emails; or
updating your marketing preferences on our website.]
We may ask you to confirm or update your marketing preferences if you ask us to provide further products and services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and will obtain your express opt-in consent before we share your personal data with any third party for marketing purposes.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that 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.
Who we share your personal data with
We routinely share personal data:
with our subsidiary companies [insert details];
other third parties we use to help us run our business and deliver our services, e.g. marketing agencies or website hosts or cloud servers;
credit reference agencies;
our insurers and brokers;
our bank.
We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.
We may also need to:
share personal data with external auditors to ensure compliance with legal and regulatory requirements;
disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations;
share some personal data with other parties, such as potential buyers of some or all of our business or during a restructuring—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations.
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
Where your personal data is held
Personal data may be held at our offices and those of our subsidiaries, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).
Some of these third parties may be based outside the UK. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK’.
How long your personal data will be kept
We will keep your personal data while you have an account with us or we are providing products and services to you. Thereafter, we will keep your personal data for as long as is necessary:
to respond to any questions, complaints or claims made by you or on your behalf;
to notify you of any health or safety risk in relation to any of the products that have been delivered to you
to show that we treated you fairly;
to keep records required by law.
We will not keep your personal data for longer than necessary. Different retention periods apply for different types of personal data. When it is no longer necessary to keep your personal data, we will delete or anonymise it.
Transferring your personal data out of the UK
To deliver services to you, it is sometimes necessary for us to share your personal data outside the UK, for example:
with other Chesamel companies based outside of the UK;
with our service providers located outside the UK;
if you are based outside the UK.
Under data protection law, we can only transfer your personal data to a country or international organisation outside the UK where:
the UK government has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an ‘adequacy decision’);
there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
a specific exception applies under data protection law
Transfers with appropriate safeguards
Where there is no adequacy decision, we may transfer your personal data to another country if we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects.
The safeguards will usually include using legally-approved standard data protection contract clauses in the form of an international data transfer agreement.
If you would like further information about data transferred outside the UK, please us (see ‘How to contact us’ below).
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
Your rights
You have the following rights, which you can exercise free of charge at any time:
Access
The right to be provided with a copy of your personal data
Rectification
The right to require us to correct any mistakes in your personal data
Erasure (also known as the right to be forgotten)
The right to require us to delete your personal data, in certain situations
Restriction of processing
The right to require us to restrict processing of your personal data in certain circumstances, for example, if you contest the accuracy of the data
Data portability
The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party, in certain situations
To object
The right to object:
at any time to your personal data being processed for direct marketing (including profiling);
in certain other situations to our continued processing of your personal data, for example, processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision making
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
For further information on each of those rights, or if you would like to exercise any of these rights, please contact us (see ‘How to contact us’ below).
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.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We also have security procedures in place as well as technical and physical restrictions to access to ensure the your personal data is safeguarded at all times.
We have procedures in place to deal with any data security breach. We will notify you and any applicable regulator of a data security breach where we are legally required to do so.
How to make a complaint
Please contact us if you have any query or concern about our use of your information (see below How to contact us’). We hope we will be able to resolve any issues you may have.
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 contact us in the first instance.
Changes to this Policy
We may change this privacy notice from time to time. Please ensure that you regularly check this privacy policy for any changes that may affect you.
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
How to contact us
You can contact us and our data protection manager by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
Address:
Pound House, 62a Highgate High Street, London, England, N6 5HX
Email address:
info@thesybarite.org