Question 1

1.   Contact details

Accepted Answer

Postal address:
			Christian House
			Rosefarm
			CROMARTY
			Ross-Shire
			IV11 8XU
			United Kingdom

Telephone:		0141 353 9550
Email:		you@happistuff.com

Question 2

2.   What information we collect, use, and why

Accepted Answer

We collect or use the following information to provide services and goods, including delivery:

• Names and contact details
 • Addresses
 • Purchase or account history
 • Payment details (including card or bank information for transfers and direct debits)
 • Account information
 • Website user information (including user journeys and cookie tracking)
 • Photographs or video recordings
 • Records of meetings and decisions
 • Information relating to compliments or complaints

We also collect or use the following special category information to provide services and goods, including delivery. This information is subject to additional protection due to its sensitive nature:

• Religious or philosophical beliefs

We collect or use the following information for the operation of customer accounts and guarantees:

• Names and contact details
 • Addresses
 • Payment details (including card or bank information for transfers and direct debits)
 • Purchase history
 • Account information, including registration details
 • Information used for security purposes
 • Marketing preferences

We collect or use the following information for service updates or marketing purposes:

• Names and contact details
 • Addresses
 • Marketing preferences
 • Location data
 • Recorded images, such as photos or videos
 • Purchase or viewing history
 • IP addresses
 • Website and app user journey information
 • Records of consent, where appropriate

We collect or use the following information to comply with legal requirements:

• Name
 • Contact information
 • Financial transaction information
 • Any other personal information required to comply with legal obligations

We collect or use the following personal information for dealing with queries, complaints or claims:

• Names and contact details
 • Address
 • Payment details
 • Account information
 • Purchase or service history
 • Relevant information from previous investigations
 • Customer or client accounts and records
 • Financial transaction information
 • Correspondence

Question 3

3.    Lawful bases and data protection rights

Accepted Answer

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases (https://ico.org.uk/for-organisations/advice-for-small-organisations/getting-started-with-gdpr/data-protection-principles-definitions-and-key-terms/#lawfulbasis)in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights, which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

• Your right of access - You have the right to ask us for copies of your personal information. You can request other information, such as details about where we get personal information from and who we share personal information with. There are some exemptions, which means you may not receive all the information you ask for. Read more about the right of access.(https://ico.org.uk/for-organisations/advice-for-small-organisations/privacy-notices-and-cookies/create-your-own-privacy-notice/your-data-protection-rights/#roa)

• Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.(https://ico.org.uk/for-organisations/advice-for-small-organisations/privacy-notices-and-cookies/create-your-own-privacy-notice/your-data-protection-rights/#rtr)

• Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.(https://ico.org.uk/for-organisations/advice-for-small-organisations/privacy-notices-and-cookies/create-your-own-privacy-notice/your-data-protection-rights/#rte)

• Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.(https://ico.org.uk/for-organisations/advice-for-small-organisations/privacy-notices-and-cookies/create-your-own-privacy-notice/your-data-protection-rights/#rtrop)

• Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.(https://ico.org.uk/for-organisations/advice-for-small-organisations/privacy-notices-and-cookies/create-your-own-privacy-notice/your-data-protection-rights/#rto)

• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.(https://ico.org.uk/for-organisations/advice-for-small-organisations/privacy-notices-and-cookies/create-your-own-privacy-notice/your-data-protection-rights/#rtdp)

• Your right to withdraw consent – When we use consent as our lawful basis, you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.(https://ico.org.uk/for-organisations/advice-for-small-organisations/privacy-notices-and-cookies/create-your-own-privacy-notice/your-data-protection-rights/#rtwc)

If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for the collection and use of your data:

Our lawful bases for collecting or using personal information to provide services and goods are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

• Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

We collect your telephone/mobile number for one-to-one services delivered online via Zoom, so we can contact you in the case of an interruption to services or loss of connection and take every possible step to fulfil our service contract by the original means or an alternative. 
For more information on our use of legitimate interests as a lawful basis, you can contact us using the contact details set out above.

Our lawful bases for collecting or using personal information for the operation of customer accounts and guarantees are:
 • Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information for service updates or marketing purposes are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information for legal requirements are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
 • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

• Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.

• Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

• Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Question 4

4.   Where we get personal information from

Accepted Answer

• Directly from you
 • Publicly available sources
 • Providers of marketing lists and other personal information

Question 5

5.   How long we keep information for

Accepted Answer

We will retain your data only for as long as necessary to fulfil the purpose it was collected for (as detailed above). Typically, we will store your name, address, billing address, order history, and correspondence (including images and related records) for a period of six years, in accordance with legal requirements such as accounting law.

Regarding sensitive and other information submitted for the Huddle via “Chirps & Honks” submission form, this will be deleted after account verification and summarisation of the material's non-specific context and gist, usually within 24 hours of review.

Telephone/mobile numbers used with legitimate interest for one-to-one online Zoom services will be deleted following delivery of the service.

Information in the form of handwritten notations or session recordings (for training and to improve our services) relating to our one-to-one online Zoom services will be deleted when reviewed (typically within 48 hours) or within 10 days, whichever is sooner.

For more information on how long we store your personal information or the criteria we use to determine this, please contact us using the details provided above.

Question 6

6.   Who we share information with

Accepted Answer

Data processors:

Wix.com
This data processor does the following activities for us: they host, enable, store and process orders, bookings, payments, and all other services (to the fullest extent) on our website.
You can view Wix’s privacy policy here: www.wix.com/about/privacy(http://www.wix.com/about/privacy)

Royal Mail, UK
This data processor does the following activities for us: they process all our deliveries.
You can view Royal Mail’s privacy policy here: www.royalmail.com/privacy-notice(http://www.royalmail.com/privacy-notice)

SumUp Payments Limited, UK
This data processor does the following activities for us: they process all our offline payments.
Others we share personal information with:

• Organisations we’re legally obliged to share personal information with

Question 7

7.   Sharing information outside the UK

Accepted Answer

Where necessary, our data processors may share personal information outside of the UK. When doing so, they comply with the UK GDPR, making sure appropriate safeguards are in place.
For further information or to obtain a copy of the appropriate safeguard for any of the transfers below, please contact us using the contact information provided above.

Organisation name: Wix.com
Category of recipient: Website platform and payment processor
Countries the personal information is sent to: the United States of America and Ireland. Wix also has group companies and third-party processors worldwide, so personal information may be processed in other countries if necessary.
How the transfer complies with UK data protection law: The country or sector has been assessed as providing adequate protection to data subjects (also known as Adequacy Regulations or UK data bridge)
Organisation name: SumUp Payments Limited
Category of recipient: Offline payment processor
Country the personal information is sent to: European Union
How the transfer complies with UK data protection law: The country or sector has been assessed as providing adequate protection to data subjects (also known as Adequacy Regulations or UK data bridge)

Question 8

8.   How to complain

Accepted Answer

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:
           
Information Commissioner’s Office
 Wycliffe House
 Water Lane
 Wilmslow
 Cheshire
 SK9 5AF

Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint(https://ico.org.uk/make-a-complaint/)