1.1 We are committed to safeguarding the privacy of our website visitors, service users, individual customers and customer personnel.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the collection, sharing and publication of your personal data.
1.5 In this policy, “we”, “us” and “our” refer to The Escape Roomer.
2.1 This document was created using a template from Docular (https://seqlegal.com/free-legal-documents/privacy-policy).
3.The personal data that we collect
3.1 In this Section 3 we have set out the general categories of personal data that we process.
3.2 We may process data enabling us to get in touch with you (“contact data“). The contact data may include your name, email address and/or social media account identifiers. The source of the contact data is you. If you log into our website using a social media account, we will obtain elements of the contact data from the relevant social media account provider.
3.3 We may process your (“account data“). The account data may include your account identifier, name, email address, business name, account creation and modification dates, website settings and marketing preferences. The primary source of the account data is yo, although some elements of the account data may be generated by our website. If you log into our website using a social media account, we will obtain elements of the account data from the relevant social media account provider.
3.4 We may process information relating to transactions, including purchases of goods and/or services, that you enter into with us and/or through our website (“transaction data“). The transaction data may include your name, your contact details, your payment details or other payment details and the transaction details. The source of the transaction data is you and/or our payment services provider.
3.5 We may process information contained in or relating to any communication that you send to us or that we send to you “communication data“. The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.
3.6 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.
4.Purposes of processing and legal bases
4.1 In this Section 4, we have set out the purposes for which we may process personal data and the legal bases of the processing.
4.2 Operations – We may process your personal data for the purposes of operating our website, the processing and fulfilment of orders, providing our services, supplying our goods, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business.
4.3 Publications – We may process account data for the purposes of publishing such data on our website and elsewhere through our services in accordance with your express instructions. The legal basis for this processing is consent.
4.4 Relationships and communications – We may process contact data, account data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests.
4.5 Research and analysis – We may process [usage data and/or transaction data] for [the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business]. The legal basis for this processing is [consent] OR [our legitimate interests, namely [monitoring, supporting, improving and securing our website, services and business generally]] OR [[specify basis]].
5.Providing your personal data to others
5.2 Your personal data held in our website database.
5.3 We may disclose transaction information to our suppliers (Etsy, Printing Company) insofar as reasonably necessary to send products.
5.4 Financial transactions relating to our website and services may be handled by our payment services providers, Etsy. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
5.5 In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
6.International transfers of your personal data
6.1 In this Section 6, we provide information about the circumstances in which your personal data may be transferred to a third country under UK and/or EU data protection law.
6.2 We may transfer your personal data from the European Economic Area (EEA) to the UK and process that personal data in the UK [for the purposes set out in this policy][, and may permit [our suppliers and subcontractors] to do so,] during any period with respect to which the UK is not treated as a third country under EU data protection law or benefits from an adequacy decision under EU data protection law; and we may transfer [your personal data] from the UK to the EEA and process that personal data in the EEA [for the purposes set out in this policy][, and may permit [our suppliers and subcontractors] to do so,] during any period with respect to which EEA states are not treated as third countries under UK data protection law or benefit from adequacy regulations under UK data protection law.
6.3 The hosting facilities for our website are situated in the UK. The competent data protection authorities have made an adequacy determination with respect to the data protection laws of each of these countries. Transfers to the UK will be protected by appropriate safeguards.
7.Retaining and deleting personal data
7.1 This Section 7 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
7.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
7.3 We will retain your personal data as follows:
(a) Contact data will be retained for a minimum period of 6 months following the date of the most recent contact between you and us, and for a maximum period of 12 months following that date];
(b) [account data will be retained for a minimum period of 6 months following the date of closure of the relevant account, and for a maximum period of 6 months following that date];
(c) [transaction data will be retained for a minimum period of 6 months following the date of the transaction, and for a maximum period of 6 months following that date];
(d) [communication data will be retained for a minimum period of 6 months following the date of the communication in question, and for a maximum period of 6 months following that date];
(e) [usage data will be retained for 6 months following the date of collection]
7.4 Notwithstanding the other provisions of this Section 7, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
8.1 In this Section 8, we have listed the rights that you have under data protection law.
8.2 Your principal rights under data protection law are:
(a) the right to access – you can ask for copies of your personal data;
(b) the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure – you can ask us to erase your personal data;
(d) the right to restrict processing – you can ask us to restrict the processing of your personal data;
(e) the right to object to processing – you can object to the processing of your personal data;
(f) the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
(h) the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
8.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting [https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/].
8.4 You may exercise any of your rights in relation to your personal data [by written notice to us, using the contact details set out below].
9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
9.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
9.3 Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
10.Cookies that we use
11.Cookies used by our service providers
12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647 (Chrome);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
12.2 Blocking all cookies will have a negative impact upon the usability of many websites.
12.3 If you block cookies, you will not be able to use all the features on our website.
13.1 We may update this policy from time to time by publishing a new version on our website.
13.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
14.1 This website is owned and operated by Mairi Nolan.
14.2 Our principal place of business is in London, UK
14.4 You can contact us by email at firstname.lastname@example.org