Monarch Caviar Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.mhcaviar.com will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is requested upon entry.
In this Policy the following terms shall have the following meanings:
“Account”
means an account required to access and/or use certain areas and features of Our Site;
“Cookie”
means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and
“Cookie Law”
means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
Our Site is owned and operated by Monarch Caviar Limited, a limited company, regis-tered in England under company number 12277020.
This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identi-fier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
Under the Data Protection Legislation, you have the following rights, which we will al-ways work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
b) The right to access the personal data we hold about you. Part 13 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to withdraw consent. This means that, if we are relying on your con-sent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
h) The right to data portability. This means that, if you have provided personal da-ta to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
i) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Com-missioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.
Depending upon your use of Our Site, we may collect and hold some or all of the per-sonal data set out in the table below, using the methods also set out in the table. Please also see Part 14 for more information about our use of Cookies and similar technologies. We do not collect any ‘special category’ or ‘sensitive’ personal data.
Data Collected
How We Collect the Data
Name
Upon checkout
Delivery address
Upon checkout
Email address
Upon checkout and/or mailing list subscription
Telephone number
Upon checkout
Under the Data Protection Legislation, [we] OR [I] must always have a lawful basis for using personal data. The following table describes how [we] OR [I] [will] OR [may] use your personal data, and [our] OR [my] lawful bases for doing so:
What We Do
What Data We Use
Our Lawful Basis
Supplying our products to you
Name, delivery address, email address, telephone number
To fulfil our sale of goods contract
Managing payments for our products
Name, delivery address, email address, telephone number
To fulfil our sale of goods contract
Communicating with you
Email address, telephone number
To fulfil our sale of goods contract
Supplying you with infor-mation by email that you have opted-in-to (you may opt-out at any time by email)
Email address
To provide with updates and special offers regarding new and existing products
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with infor-mation, news, and offers on our products and services. You will not be sent any un-lawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Elec-tronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before shar-ing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
We use the following automated system for carrying out certain kinds of decision-making. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action them-selves, rather than relying only on the automated method), the Data Protection Legis-lation gives you the right to do so. Please contact us to find out more using the details in Part 15.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that pur-pose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.
If we need to use your personal data for a purpose that is unrelated to, or incom-patible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
Type of Data
How Long We Keep It
Name
Indefinitely and for statistical purposes
Delivery address
Indefinitely and for statistical purposes
Email address
Indefinitely and for statistical purposes
Telephone number
Indefinitely and for statistical purposes
Purchase history
Indefinitely and for statistical purposes
We will store some of your personal data in the UK. This means that it will be fully pro-tected under the Data Protection Legislation.
AND
We will store some of your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liech-tenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.The security of your personal data is essential to us and to protect your data, we take a number of important measures, including the following:
limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
procedures for dealing with data breaches (the accidental or unlawful destruc-tion, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.
We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.
If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Priva-cy Policy.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
We may share your personal data with other companies in our group for statistical purposes. This includes subsidiaries and our holding company and its subsidiaries.
We may sometimes contract with the following third parties to supply certain products and services.
Recipient
Activity Carried Out
Sector
Location
Mailchimp
Sending out information and offers
Email software
Atlanta, Georgia, United States
Stripe
Processing your payments for our goods and services
Online payment solutions
Dublin, Ireland
Google Analytics
Analysing website efficiencies / deficiencies
IT
Dublin, Ireland
Trustpilot
Collecting reviews of your experiences
IT
Copenhagen, Denmark
If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in ac-cordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.
If any personal data is transferred outside of the UK, we will take suitable steps in or-der to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 9.
If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Priva-cy Policy.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
1.
In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to re-strict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscrib-ing using the links provided in our emails and at the point of providing your de-tails.
2.
You may also wish to sign up to one or more of the preference services oper-ating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Ser-vice (“the MPS”). These may help to prevent you receiving unsolicited market-ing. Please note, however, that these services will not prevent you from receiv-ing marketing communications that you have consented to receiving.
You may access certain areas of our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
You may restrict our use of Cookies. For more information, see Part 14 and our Cookie Policy.
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. To make this as easy as possible for you, a Subject Ac-cess Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within less than one month and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
Our Site may place and access certain first-party Cookies on your computer or de-vice. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our products and services We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and re-spected at all times.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a <<insert description of prompt, e.g. pop-up>> requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.
Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by al-lowing them.
The following first-party Cookies may be placed on your computer or device:
Name of Cookie
Purpose
Strictly Necessary
<<insert file name>>
<<insert description>>
<<yes / no>>
<<insert file name>>
<<insert description>>
<<yes / no>>
<<insert file name>>
<<insert description>>
<<yes / no>>
<<insert file name>>
<<insert description>>
<<yes / no>>
<<insert file name>>
<<insert description>>
<<yes / no>>
Our Site uses analytics services provided by <<insert name(s) of analytics service provider(s)>>. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Site is used. This, in turn, enables us to improve Our Site and the products and services offered through it.
The analytics service(s) used by Our Site use(s) Cookies to gather the required in-formation. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable us to continually improve Our Site, making it a better and more useful experi-ence for you.T
he analytics service(s) used by Our Site use(s) the following Cookies:
Name of Cookie
First / Third Party
Provider
Purpose
<<insert file name>>
<<first / third>>
<<insert name>>
<<insert description>>
<<insert file name>>
<<first / third>>
<<insert name>>
<<insert description>>
<<insert file name>>
<<first / third>>
<<insert name>>
<<insert description>>
<<insert file name>>
<<first / third>>
<<insert name>>
<<insert description>>
<<insert file name>>
<<first / third>>
<<insert name>>
<<insert description>>
In addition to the controls that we provide, you can choose to enable or disable Cook-ies in your internet browser. Most internet browsers also enable you to choose wheth-er you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your de-vice.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your in-ternet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
To contact us about anything to do with your personal data and data protection, includ-ing to make a subject access request, please use the following details:
Email address: monarch@mhcaviar.com
Telephone number: +44 20 8168 1221
Postal Address: 55 Victoria Street, SW1H 0EU, London, United Kingdom
We may change this Privacy Notice fromtime to time. This may be necessary, for example, if the law changes, or if wechange our business in a way that affects personal data protection.
Any changes will be immediately posted on OurSite and you will be deemed to have accepted the terms of the PrivacyPolicy on your first use of Our Site following the alterations. We recommendthat you check this page regularly to keep up-to-date. This Privacy Policy waslast updated on 31/01/2021.
