PRIVACY NOTICE

1. IMPORTANT NOTICE

This is the Privacy Notice of Ventete Limited (company number 09195223) whose registered office is at Studio Unit 19, 86 Main Yard, Wallis Road, London, England, E9 5LN (“Ventete”, “we“, “us” or “our”) and sets out how we collect and process your personal data. This Privacy Notice also provides certain information that is legally required and lists your rights in relation to your personal data. Please read this Privacy Notice to understand how we may use your personal data.

This Privacy Notice relates to personal information that identifies “you” meaning customers or potential customers and individuals who browse our website. If you are an employee, contractor or otherwise engaged in work for us or applying to work for us, a separate privacy notice applies to you instead.

This Privacy Notice is not intended for children and we do not knowingly collect personal data relating to children. Additionally, this Privacy Notice is not intended to apply to personal data collection during the recruitment of employees, for which there is a separate privacy notice.

This Privacy Notice may vary from time to time so please check it regularly. This version of this Privacy Notice was first published on [ ] 2022 and has not been updated since.

2. HOW TO CONTACT US

Controller

This Privacy Notice applies where we are a controller in respect of your personal data – this is where we decide how and why your personal data is processed.

If you wish to correct your personal data held by us or to opt out at any time from receiving marketing correspondence from us or to alter your marketing preferences, please contact info@ventete.com.

If you need to contact us in connection with our use or processing of your personal data, or gain access to it, then our contact details are info@ventete.com.

3. CATEGORIES OF PERSONAL DATA WE COLLECT

The categories of personal data about you that we may collect, use, store, share and transfer are:

• Individual Data. This includes personal data which relates to your identity, such as your first name, middle name, last name, username or similar identifier, marital status, title, date of birth and gender and your contact details such as your billing address, delivery address, email address and telephone numbers.
• Advertising Data. This includes personal data which relates to your advertising preferences, such as information about your preferences in receiving marketing materials from us and our third parties and your communication preferences.
• Information Technology Data. This includes personal data which relates to your use of our website, such as your internet protocol (IP) address, login data, traffic data, weblogs and other communication 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.
• Account and Profile Data. This includes personal data which relates to your account or profile on our website, such as your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Economic and Financial Data. This includes personal data which relates to your finances, such as your bank account and payment card details and information which we collect from you for the purposes of the prevention of fraud.
• Sales Data. This includes personal data which relates to the transactions you have conducted with us, such as details about payments to and from you, details of subscriptions to our publications and other details of products and services you have purchased from us.
• Market Research Data. This includes personal data which is gathered for the purposes of market research, such as price comparison information, opinions on specific products and services offered by us or the general market, your interests, opinions, and preferences, age, income bracket, and other personal details you willingly share within the context of a survey, customer interview or similar.
• Social Media Data. This includes how you engage with our social media accounts, for example whether you like, follow, or comment on our Instagram posts, re-tweet our Twitter posts, and the like.
• Customer Service Outreach Data. This includes personal data gathered through outreach through our customer service contact form, social media, help@ventete.com, info@ventete.com, or similar addresses regarding your experiences with our products and services, with the aim of providing support with these.

We may also create Personal Data about you, for example, if you contact us by telephone to make a complaint, for example about our goods, then we may make a written record of key details of the conversation so that we can take steps to address the complaint.

We also obtain and use certain aggregated data such as statistical or demographic data (“Aggregated Data”) for any purpose. Aggregated Data may be derived from your personal data but does not directly or indirectly reveal your identity. For example, we may aggregate your Information Technology Data to calculate the percentage of users accessing a specific feature on our website. However, if we re-combine or re-connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.

4. THE SOURCES FROM WHICH WE OBTAIN YOUR PERSONAL DATA

We obtain your personal data from the following sources:

• Directly from you, via our website, email contacts, in person or by telephone. This could include personal data which you provide when you:
• place an order for our products;
• create an account on our website;
• request information on our products or services or for other marketing to be sent to you;
• enter into a competition or promotion;
• attend an in-person event hosted by us; or
• complete a survey from us or give us feedback.

• From someone else, such as:
• analytics providers (such as Google);
• publications providers (such as Klayvio);
• reviews providers (such as [Yotpo]);
• advertising networks (such as Google);
• search information providers (such as Google, Bing);
• providers of technical, payment and delivery services (such as Shopify); or
• providers of social media platforms (such as Facebook, TikTok, Twitter and Instagram) for example where you share our content through social media, for example by liking us on Facebook, following or tweeting about us on Twitter, commenting on an Instagram post.

5. HOW WE USE YOUR PERSONAL DATA

We collect personal data about you in order to:

• perform our contractual obligations to you. This would include:
• processing and performing any orders placed by you;
• orders placed by us where you are a supplier;
• making or receiving payments, fees and charges; and
• collecting and recovering money owed.
• manage our relationship with you including:
• to send you important notices such as communications about changes to our terms and conditions and policies (including this Privacy Notice);
• to provide you with important real-time information about products or services you have ordered from us (e.g. a change of time or location due to unforeseen circumstances);
• to send you information you have requested;
• to deal with your enquiries;
• to ask you to leave a review or feedback on us; and;
• to ask you to complete a survey fielded by us.
• administer our business and carry out business activities;
• process and perform warranty claims made by you or returns requested by you;
• make suggestions and recommendations to you about goods or services from us or carefully selected third parties that may be of interest to you, deliver relevant website content and advertisements to you and to measure or understand the effectiveness of our advertising;
• communicate with you about, and administer your participation in, special events;
• for internal purposes to use data analytics, to identify usage trends, determine and measure the effectiveness of promotional campaigns and advertising and to improve our website, products/services, marketing, customer relationships and experiences;
• protect our business including to deal with any misuse of our website and to comply with our security policies at our locations;
• use your personal data to comply with our own legal obligations e.g. to comply with health and safety requirements, or to assist in a police investigation;
• enforce or apply our terms of use, terms and conditions of supply and other agreements with third parties;
• to detect and prevent fraud and other illegal activities (and to assist regulators, trade bodies and law enforcement agencies in relation to the same);
• finance, restructure, sell, make ready for sale or dispose of our business in whole or in part including to any potential buyer or their advisers;
• use our knowledge of any personal data you disclose to us in the event of illness or injury or some other related emergency or to record any accident or injury or other incident you may suffer when visiting any of our locations; and
• investigate and defend any third-party claims or allegations.

6. OUR LAWFUL BASIS FOR PROCESSING YOUR PERSONAL DATA

Where we may rely on consent

For certain purposes it may be appropriate for us to obtain your prior consent. The legal basis of consent is only used by us in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way.

In the event that we rely on your consent, you may at any time withdraw the specific consent you give to our processing your personal data. Please contact us using the contact details set out in paragraph 1 to do so. Please note even if you withdraw consent for us to use your personal data for a particular purpose we may continue to rely on other lawful bases to process your personal data for other purposes.

Examples of when we may rely on your consent to process your personal data include:

• where we would like to use photos or images taken of you or by you in promotional materials;
• where we would like to share our email publication with you, including information about our existing or new products and services, carefully selected third party partnerships or collaborations, or similar; and
• where we or our carefully selected third parties have new products and/or services which we think you may be interested in.

Other legal bases we may rely on

Where we are relying on a basis other than your consent, the lawful basis for processing personal data will be one of the following:

• the processing is necessary in order for us to comply with our legal obligations (such as compliance with anti-money laundering legislation);
• the processing is necessary for the performance of a contract you are party to or in order to take steps at your request prior to you entering into a contract;
• the processing is necessary for the establishment, exercise or defence of legal claims; or
• the processing is necessary for the pursuit of our legitimate business interests. In particular, our legitimate interests include:
• the provision of goods and services;
• the recovery of debt; the provision of administration and / or IT services;
• the security of our IT network;
• the prevention of fraud;
• the marketing of goods and services and promotion of our business;
• the reorganisation or sale or refinancing of the business;
• the study in how to develop and update our products and services;
• the development of our business strategy;
• protecting our business and property;
• the processing is necessary in order to protect the vital interests of an individual e.g. where there is a medical emergency at one of our premises.

Extra conditions for sensitive personal data

Where we are processing your sensitive / special category personal data one of the following conditions will also apply:

• you have given your explicit consent to the processing;
• the processing relates to personal data which was manifestly made public by you; and
• the processing is necessary for the establishment, exercise or defence of legal claims.

7. WHO RECEIVES YOUR PERSONAL DATA

We may disclose your personal data to:

• our group companies and affiliates and/or third party data processers who may process data on our behalf to enable us to carry out our usual business practices. Any such disclosure will only be so that we can process your personal data for the purposes set out in this Privacy Notice;
• HMRC, legal and other regulators or authorities, including those who request your personal data or to report any potential or actual breach of applicable law or regulation;
• external professional advisers such as accountants, consultants, bankers, insurers, auditors and lawyers;
• law enforcement agencies, courts or other relevant party, to the extent necessary for the establishment, exercise or defence of legal rights;
• third parties where necessary for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;
• third parties which are considering or have decided to acquire some or all of our assets or shares, merge with us or to whom we may transfer our business (including in the event of a reorganisation, dissolution or liquidation), and their external professional advisers and providers of finance;
• third parties operating plugins or content (such as Facebook, Twitter, Instagram) on our website which you choose to interact with;
• the following recipients:
• Shopify;
• Google Analytics;
• Klayvio;
• Yotpo;
• Google Ads; and
• Microsoft Ads.

8. PERSONAL DATA ABOUT OTHER PEOPLE WHICH YOU PROVIDE TO US

If you provide personal data to us about someone else (such as one of your directors or employees, or someone with whom you have business dealings) you must ensure that you are entitled to disclose that personal data to us and that, without our taking any further steps, we may collect, use and disclose that personal data as described in this Privacy Notice.

You must ensure the individual concerned is aware of the various matters detailed in this Privacy Notice, as those matters relate to that individual, including our identity, how to contact us, the way in which we collect and use personal data and our personal data disclosure practices, that individual’s right to obtain access to the personal data and make complaints about the handling of the personal data, and the consequences if the personal data is not provided.

9. ACCURACY OF YOUR PERSONAL INFORMATION

It is important that the personal data we hold about you is accurate and current and we take all reasonable precautions to ensure that this is the case but we do not undertake to check or verify the accuracy of personal data provided by you. Please keep us informed if your personal data changes during your relationship with us by contacting us. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.

10. INTERNATIONAL TRANSFERS OF PERSONAL DATA

It is possible that personal data we collect from you may be transferred, stored and/or processed outside the United Kingdom including outside the European Economic Area and including to the United States of America.

In connection with such transfers we will ensure that:

• there are appropriate safeguards in place such as binding corporate rules or approved model contractual clauses. A relevant copy of the appropriate safeguard can be obtained by contacting us using the contact details set out in paragraph 2; or
• the transfer is to a country that provides an adequate level of protection; or
• one of the derogations for specific situations applies to the transfer including explicit consent or that it is necessary for the performance of a contract or exercise or defence of legal claims.

11. HOW LONG WE WILL STORE YOUR PERSONAL DATA FOR

We will store your personal data for the time period which is appropriate in accordance with our data retention policy which can be obtained by contacting us using the contact details set out in paragraph 2.

12. CONTRACTUAL OR STATUTORY REQUIREMENTS ON YOU TO PROVIDE PERSONAL DATA

In certain circumstances the provision of personal data by you is a requirement to comply with the law or a contract, or necessary to enter into a contract.

It is your choice as to whether you provide us with your personal data necessary to enter into a contract or as part of a contractual requirement. If you do not provide your personal data then the consequences of failing to provide your personal data are that we may not be able to perform to the level you expect under our contract with you. An example of this would be where we are unable to provide you with certain products or services as we do not have your full details, or where we cannot perform our contract with you at all because we rely on the personal data you provide in order to do so.

13. YOUR RIGHTS IIN RELATION TO YOUR PERSONAL DATA

Subject to applicable law including relevant data protection laws, in addition to your ability to withdraw any consent you have given to our processing your personal data (see paragraph 6), you may have a number of rights in connection with the processing of your personal data, including:

• the right to request access to your personal data that we process or control;
• the right to request rectification of any inaccuracies in your personal data or, taking into account the purposes of our processing, to request that incomplete data is completed;
• the right to request, on legitimate grounds as specified in law:
• erasure of your personal data that we process or control; or
• restriction of processing of your personal data that we process or control;
• the right to object, on legitimate grounds as specified in law, to the processing of your personal data;
• the right to receive your personal data in a structured, commonly used and machine-readable format and to have your personal data transferred to another controller, to the extent applicable in law; and
• the right to lodge complaints regarding the processing of your personal data with the United Kingdom’s Information Commissioner’s Office or the equivalent data protection supervisory authority in the country where you think we have infringed upon your data protection rights. Please see https://ico.org.uk/concerns/ for how to do this in the United Kingdom.

If you would like to exercise any of the rights set out above, please contact us using the contact details set out in paragraph 2.

14. LINKS TO OTHER WEBSITES

This Privacy Notice only applies to us. If you link to another website from our website, you should remember to read and understand that website’s privacy policy as well. We do not control unconnected third-party websites and are not responsible for any use of your personal data that is made by unconnected third party websites.