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Privacy Policy

INTRODUCTION

Alchemy Worldwide Limited (“we“, “our” and “us“) is committed to protecting and respecting your privacy and personal information. This policy sets out the basis on which any personal information, which we collect from you, that you provide to us or that we have received from a third party source, will be processed by us.

This policy also sets our your relevant legal rights and you should refer to section 11 for this information. In particular, if you have questions about correcting or deleting your personal data (including if you would no longer like to receive marketing communications from us) please refer to sections 11 and 16 below.

1  DEFINITIONS

References in this policy to “data protection law” mean (as applicable from time to time) the Data Protection Act 1998, the General Data Protection Regulation (Regulation (EU) 2016/679) and all related data protection legislation having effect in the United Kingdom from time to time.

References in this policy to “data or “information” include “sensitive personal data” and “special categories of data” (as defined under data protection law), where applicable.

2 OUR DETAILS

For the purposes of data protection law, Alchemy Worldwide Limited is the data controller with conduct of your information. Our address is 25 St Thomas Street, Winchester, SO23 9HJ.

Our Data Protection Officer is Tessa Sharp of Alchemy Worldwide Limited, 25 St Thomas Street, Winchester, SO23 9HJ and whose email address is info@alchemyww.com.

3 THIRD PARTY SITES

Our website may, from time to time, contain links to and from partners’, advertisers’, affiliates’ and social network sites. If you follow a link to any of these websites, please note that these sites have their own privacy policies and that we do not accept any responsibility or liability for those policies. Please check their privacy policies before you submit any personal data to those websites as they may not be on the same terms as ours.

4 SOURCES AND USE OF PERSONAL INFORMATION

Depending on your relationship to us, we obtain, process, store and share your information in different ways. We have separated these relationships into three categories:

  1. Individual clients, customers and suppliers;
  2. Workers or representatives of customers and suppliers; and
  3. Associates and business partners.

5 INDIVIDUAL CUSTOMERS AND SUPPLIERS

5.1 Sources and types of information we hold about you

Where you are a client, customer or supplier of ours and you are also an individual, we:

  1. Collect information about you directly. This includes where you fill in a form on our website, make a purchase from us, contact us directly (such as by telephone, post or email) or give your details to one of our employees or representatives in person.
  2. Collect information about you from third parties For suppliers this will typically be where we have been referred to you by a third party intermediary or where you operate as a sole trader or partnership and we receive information about you from an employee or business partner of yours. For customers, we may receive information about you from third parties where you have consented to them sharing your information with us.
  3. Collect information about you through the use of our website Through our website, we collect non-personally identifying information which web browsers and servers typically make available. This includes technical information, such as your IP address, your login information and information about your visit, such as records of how you navigate the pages on our site and how you interact with the pages. For details on how we use cookies, please see section 12 below.

The types of information we hold about you will typically include your name, address, email address, telephone number and in some circumstances information about learning requirements and the organisation you work for.

If you are a customer of ours then we may, in certain circumstances, process sensitive personal information about your dietary requirements, allergies, or other health information.

5.2 Reasons and grounds for processing your information

We process your information:

    1. If you are a client, customer or potential customer, to supply you with details of our products and services where you have requested these from This includes taking pre-contractual steps such as providing you with a price quote.
    2. If you are a customer or potential customer, to store your information on our customer database for marketing purposes and, where you have opted into receiving the same, and/or where we have a legitimate interest in doing so, to send you marketing communications concerning our product and service offerings.
    3. If you are a customer, to administer your account with us, including in certain circumstances, refunding money to you.
    4. If you are a customer and you have provided us with dietary, allergy or other health information, to ensure we accommodate your relevant requirements.
    5. If you are a customer or a supplier, to comply with our record keeping, regulatory and other legal compliance responsibilities.

If you are a customer or a supplier, to administer any dispute or potential for dispute between us.

  1. If you are a supplier, to administer the contractual relationship between us, including taking pre-contractual steps such as obtaining a price quote from you.

Under data protection law we carry out this processing on the following grounds:

  1. The processing is necessary for us to provide you with the products or services requested from us, including us carrying out any pre-contractual steps we have been instructed to take (such as providing you with a fee estimate or additional information about our services).
  2. The processing is otherwise necessary for the performance of a contract between us, including us taking any relevant pre-contractual steps.
  3. In the case of sending marketing materials, we have a legitimate business interest in sending you news and information about our business and that interest is not overridden by your interests and fundamental rights and freedoms (for example because you can opt-out of such materials at any time) or we otherwise have obtained your consent.
  4. In certain cases, the processing is necessary for us to comply with our legal obligations, for example where regulations oblige us to keep records of our customers’ details and account information.
  5. Where you have provided us with sensitive personal information about your diet, allergies or health, because you have previously expressly consented to us processing such information for that purpose.
  6. In the event of a dispute arising between us we have a legitimate interest in processing your personal information to resolve that dispute and we are satisfied that your interests and fundamental rights and freedoms do not override our interest in doing so.
  7. Where you are our supplier, processing your information is necessary for us to administer the contract (including any pre-contractual steps) between us.

6 WORKERS OR REPRESENTATIVES OF CUSTOMERS AND SUPPLIERS

6.1 Sources and types of information we hold about you

Where you are a worker or representative of a customer or supplier of ours then we:

  1. Collect information about you directly. This includes where you fill in a form on our website, contact us directly (such as by telephone, post or email) or give your details to one of our employees or representatives in person.
  2. Collect information about you from third parties. This is typically where another person from your organisation provides us with your details.
  3. Collect about you through the use of our w Through our website, we collect non-personally identifying information which web browsers and servers typically make available. This includes technical information, such as your IP address, your login information and information about your visit, such as records of how you navigate the pages on our site and how you interact with the pages. For details on how we use cookies, please see our ‘Cookies’ section below.

The types of information we hold about you will typically include your name, job title, address, email address and telephone number.

If you work for or represent a customer of ours then we may, in certain circumstances, process sensitive personal information about your dietary requirements, allergies, or other health information.

6.2 Reasons and grounds for processing your information

We process your information:

  1. If you work for or represent a customer or potential customer, to supply our customer with details of our products and services where these have been requested from This includes taking pre-contractual steps such as providing a price quote.
  2. If you work for or represent a customer or potential customer, to store your information on our customer database for marketing purposes and, where you have opted into receiving the same, and/or where we have a legitimate interest in doing so, send you marketing communications concerning our product and service offerings.
  3. If you work for or represent a customer, to administer the customer’s account with us, including in certain circumstances, refunding money to the customer.
  4. If you work for or represent a customer and you have provided us with dietary, allergy or other health information, to ensure we accommodate your relevant requirements.
  5. If you work for or represent a customer or a supplier, to comply with our record keeping, regulatory and other legal compliance responsibilities.
  6. If you work for or represent a customer or a supplier, to administer any dispute or potential for dispute between the customer/supplier and us.
  7. If you work for or represent a supplier, to administer the contractual relationship between the supplier and us, including taking pre-contractual steps such as maintaining a record of price quotes the supplier has provided to us and making payment to the supplier.

Under data protection law we carry out this processing on the following grounds:

  1. The processing is necessary for us to provide the customer with the products or services requested from us, including us carrying out any pre-contractual steps we have been instructed to take (such as providing a fee estimate or additional information about our services).
  2. In the case of sending marketing materials, we have a legitimate business interest in sending you news and information about our business and that interest is not overridden by your interests and fundamental rights and freedoms (for example because you can opt-out of such materials at any time) or we otherwise have obtained your consent.
  3. In certain cases, the processing is necessary for us to comply with our legal obligations, for example where regulations oblige us to keep records of our customers’ details and account information.
  4. Where you have provided us with sensitive personal information about your diet, allergies or health, because you have previously expressly consented to us processing such information for that purpose.
  5. In the event of a dispute arising between the customer/supplier and us, we have a legitimate interest in processing your personal information to resolve that dispute and we are satisfied that your interests and fundamental rights and freedoms do not override our interest in doing so.
  6. Where you are our supplier, processing your information is necessary for us to administer the contract (including any pre-contractual steps) between us.

7 ASSOCIATES AND BUSINESS PARTNERS OF OURS.

7.1 Sources and types of information we hold about you

Where you are an associate or business partner of ours, we:

  1. Collect information about you directly. This includes where you fill in a form on our website, contact us directly (such as by telephone, post or email) or give your details to one of our employees or representatives in person.
  2. Collect information about you from third parties. This is typically where another person from your organisation or a third party provides us with your details.
  3. Collect about you through the use of our w Through our website, we collect non-personally identifying information which web browsers and servers typically make available. This includes technical information, such as your IP address, your login information and information about your visit, such as records of how you navigate the pages on our site and how you interact with the pages. For details on how we use cookies, please see our ‘Cookies’ section below.

The types of information we hold about you will typically include your name, address, email address, telephone number and bank details.

We may also, in certain circumstances, process sensitive personal information about your dietary requirements, allergies, or other health information.

7.2 Reasons and grounds for processing your information

We process your information:

  1. To administer the contractual relationship between us, including (as applicable) making payment to you or receiving payment from you and taking any pre-contractual steps you have instructed us to carry out.
  2. To store it on our database for marketing purposes and, where you have opted into receiving the same, and/or where we have a legitimate interest in doing so, to send you marketing communications concerning our product and service offerings.
  3. Where you have provided us with dietary, allergy or other health information, to ensure we accommodate your relevant requirements.
  4. To comply with our record keeping, regulatory and other legal compliance responsibilities.
  5. To administer any dispute or potential for dispute between us.

Under data protection law we carry out this processing on the following grounds:

  1. The processing is necessary for the performance of the contract between us, including us taking any relevant pre-contractual steps.
  2. In the case of sending marketing materials, we have a legitimate business interest in sending you news and information about our business and that interest is not overridden by your interests and fundamental rights and freedoms (for example because you can opt-out of such materials at any time) or we otherwise have obtained your consent.
  3. Where you have provided us with sensitive personal information about your diet, allergies or health, because you have previously expressly consented to us processing such information for that purpose.
  4. In certain cases, the processing is necessary for us to comply with our legal obligations, for example where regulations oblige us to keep records of your details.
  5. In the event of a dispute arising between us we have a legitimate interest in processing your personal information to resolve that dispute and we are satisfied that your interests and fundamental rights and freedoms do not override our interest in doing so.

8 HOW LONG WE KEEP YOUR INFORMATION FOR

We only keep your information for so long as is reasonably necessary. Generally speaking, we keep your information for the following periods of time:

    1. If you make an enquiry with us but ultimately do not become a customer, supplier or associate/business partner of ours, 2 years from the date of our discussions ending (or if we did not reply, the date of your enquiry).
    2. If you are or have been a customer of ours, 6 years from the date your contract with us enquiry).
    3. If you work for or represent a customer of ours, 6 years from the date of the customer’s last contact with us (or, if sooner, from the date we are notified that you are no longer a contact for that customer).
    4. If you are or have been a supplier of ours, 6 years from the date your contract with us ends.

If you work for or represent a supplier of ours, 6 years from the date the supplier’s contract with us ended (or, if sooner, from the date we are notified that you are no longer a contact for that supplier).

  1. If you are or have been an associate or business partner of ours, 6 years from the date your contract, or other relationship, with us ends,

If we need to keep your information for a longer period then we will notify you of the reason and grounds for doing so.

9 WHO IS YOUR INFORMATION SHARED WITH?

Your personal information is not shared with anyone except where we are required to do so to comply with the law, to protect our rights, to perform our contractual obligations to you or to keep you updated of developments to our business and services.

In order to achieve these purposes, we share your data with the following people or group of people:

  1. If you are an employee of a customer or supplier of ours then we may share your information with your employ Similarly, if you are a sole trader or partner in a business partnership then we may share your information with your employees (and if applicable, other partners). This is only done to the extent necessary for us to properly provide our services.
  2. Our IT providers will sometimes be given access to our databases in order to monitor and improve our IT systems. Our IT providers have a strict contractual obligation to handle your information in accordance with data protection law and to keep it confidential at all times.
  3. Our software provider, Infusion Software, Inc. (trading as ‘Infusionsoft’) is based in the United States, i.e. outside of the EEA and European Commission approved countries, but we are authorised to transfer your information to them on the basis that they have signed the European Commission’s approved model contract claus Those model contract clauses contain strict controls on how Infusionsoft can use your information and the steps it must take to keep your information secure and confidential.
  4. Strategic Virtual Solutions Inc, d/b/a Your Online Marketing Team, a Georgia corporation located at 19990 Highway 100, Franklin, Georgia, 30217, provides us with marketing services and maintains our marketing datab Where you have opted into receiving marketing information (or we otherwise have a legitimate interest in marketing to you) we will share your personal information with Your Online Marketing Team for this purpose. Your Online Marketing Team is based in the United States, i.e. outside of the EEA and European Commission approved countries, but we are authorised to transfer your information to Your Online Marketing Team because they have signed the European Commission’s approved model contract clauses.
  5. Where you provide us with dietary or allergy information, or information about your health-related requirements, we may share that information with facility providers such as caterers (for dietary requirements), travel agents (for hotel arrangements) or venue organisers (e.g. hotels and transportation companies). You will have been notified of this fact at the point you shared that information with us (e.g. when signing our consent form). You have the right to withdraw your consent at any time, please see section 11(b) below for further information.
  6. Our professional advisers (including accountants, book keepers and lawyers). All such people are subject to strict duties of confidentiality.
  7. Potential purchasers of our business would have access to redacted information about our customers, suppliers and their workers/representatives. Before we shared such information the potential purchaser would need to sign a non-disclosure agreement which fully complies with data protection law.

Except as set out above, to the best of our knowledge, understanding and belief, your information will not be transferred outside of the European Economic Area or to any country which is not approved by the European Commission. If this changes then we will let you know.

10 AUTOMATED DECISION MAKING

As part of our marketing activities, we may carry out a form of automated processing known as ‘profiling’ to ensure that our marketing contacts receive communications which are tailored to their interests and requirements. If you would like to opt-out of us processing your information in this way then please contact us using the details set out in section 16 below.

11 YOUR RIGHTS

Under data protection law you have the following rights:

  1. the right to be informed as to what we do with your information. This includes but is not limited to the right to know what information we gather, process and store, what we do with it, who we share it with and how long we keep it for. This information is set out in this policy and you can contact us if you have any questions;
  2. if we are processing your data on the basis of your consent (i.e. where you provide us with dietary, allergy or other health information) then you have the right to withdraw that consent at any tim Consent can be withdrawn by notifying us using the details set out in section 16 below. Please note that:
    1. the lawfulness of our historic processing based on your consent will not be retrospectively affected by your withdrawal of consent; and
    2. we may be unable to provide you with our services if you withdraw your consen We will inform you if this is the case;
  3. the right to access a copy of your information which we hold. This is called a ‘subject access request’. Additional details on how to exercise this right are set out in section 13, below;
  4. the right to prevent us processing your information for direct marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purpos You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us using the details set out in section 16, below;
  5. the right to object to decisions being made about you by automated means. We will inform you if your information is subject to automated processing;
  6. the right to object to us processing your personal information in certain other situations;
  7. the right, in certain circumstances, to have your information rectified, blocked, erased or destroyed if it is inaccurate; and
  8. the right, in certain circumstances, to claim compensation for damages caused by us breaching data protection law.

From 25 May 2018 you will also have the following additional rights under data protection law:

  1. enhanced rights to request that we erase, rectify, cease processing and/or delete your information; and
  2. in certain circumstances, the right to request the information we hold on you in a machine readable format so that you can transfer it to other servic This right is called ‘data portability’. Additional details on how to exercise this right are set out in section 13, below.

You also have the general right to complain to us (in the first instance) and to the Information Commissioner’s Office (if you are not satisfied by our response) if you have any concerns about how we hold and process your information. Our contact details are set out in section 16, below. The Information Commissioner’s Office website is www.ico.org.uk.

For further information on your rights under data protection law and how to exercise them, you can contact Citizens Advice Bureau (www.citizensadvice.org.uk) or the Information Commissioner’s Office (www.ico.org.uk).

12 COOKIES

Our site uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our site and also allows us to improve our site.

Visitors to our website who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using our site. This will mean that some features of our website may not function properly without the aid of cookies.

13 ACCESS TO INFORMATION

Under data protection law you can exercise your right of access by making a written request to receive copies of some of the information we hold on you. If you make your request before 25 May 2018, you will need to pay a £10 fee. You must send us proof of your identity, and proof of authority if making the request on behalf of someone else, before we can supply the information to you. Requests should be sent to Tessa Sharp, Alchemy Worldwide Limited, 25 St Thomas Street, Winchester, SO23 9HJ or sent by email to info@alchemyww.com.

From 25 May 2018 you will:

  1. no longer have to pay a £10 fee unless you are requesting copies of documents you already possess, in which case we may charge our reasonable administrative c We will also be allowed to charge you for our reasonable administrative costs in collating and providing you with details of the requested information which we hold about you if your request is clearly unfounded or excessive. In very limited circumstances, we are also entitled to refuse to comply with your request if it is particularly onerous; and
  2. in certain circumstances, be entitled to receive the information in a structured, commonly used and machine readable form.

14 DATA SECURITY

We will always store your digital information on secure servers. Unfortunately, however, the transmission of information via the internet is not completely secure. Although we will do our best to protect your information, we cannot guarantee the security of your information transmitted to our website or otherwise to our servers (such as by email). Any such transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

15 CHANGES TO OUR PRIVACY POLICY

This policy was last updated on 11th April 2018. Any material changes we may make to our privacy policy in the future will be uploaded to our website. Please check back frequently to see any updates or changes to our privacy policy.

16 CONTACT

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to Tessa Sharp, Alchemy Worldwide Limited, 25 St Thomas Street, Winchester, SO23 9HJ or sent by email to info@alchemyww.com.