Privacy and Cookies Policy

Welcome to the Carluccio’s Limited privacy and cookies policy.

As you would expect, we respect your privacy and will always keep your data safe and secure.

This privacy and cookies policy explains how we look after your personal data when you visit our website (regardless of where you visit it from) or when you visit any of our restaurants. It will also tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary at the end of the notice to understand the meaning of some of the terms used.

Privacy and Cookies Policy

We are Carluccio’s Limited trading as: Carluccio’s. Our sister brands are Boparan Restaurant Group. This policy has been adopted by each of Carluccio’s Limited and Boparan Restaurant Group 

We respect your privacy and are committed to protecting and respecting your personal data.

We collect and use many different kinds of personal information to provide our dining experiences and services. This policy (together with any applicable terms of use and any other documents referred to on it) sets out how we collect and processes your personal data through your use of this website (including the mobile optimised version of the website accessible from your portable hand-held device), our app(s), or our in-restaurant WiFi Service, and including any data you may provide through this website when you sign up to our newsletter, book a table or take part in a competition.  

It is important that you read this policy together with any other privacy notice or fair processing notice we may provide. By visiting our website or using our WiFi Service you are accepting and consenting to the practices described in this policy. 

Any changes we make to our privacy policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy policy.

If you have any questions about this policy, including any requests to exercise your legal rights, please contact us at: contact@boparanrestaurants.com

When we collect Data

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Generally, we collect and process your information in the following ways:

  • When you make a reservation at any of our restaurants;
  • When you purchase gift vouchers;
  • When you visit or make transactions in the establishments that we own or manage;
  • When you respond to our promotions, or subscribe to our mailing lists;
  • When you participate in competitions, contests or games organised by us;
  • When you attend events or functions organised by us, or conducted at our establishments, for example, property launches, private dining, ticketed events and hosted events, promotional and marketing events and other social events;
  • When you use our services (or express an interest in doing so) including services and transactions in respect of properties that we own or manage;
  • When you communicate with us by telephone, email, via our website or through other communication channels, for example, through social media platforms;
  • When you visit our website, or register a user account with our website or mobile applications;
  • When we seek information about you and receive your personal data in connection with your relationship with us; and
  • When you submit your personal data to us for any other reason.

The Data we collect

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Information you give us. This is information about you that you give us by filling in forms on our website or app(s), or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site; use our restaurant WiFi Service; search for a restaurant; book a table at one of our restaurants; participate in discussion boards or other social media functions on our site; enter a competition promotion or survey; request marketing, subscribe to publications/newsletters and when you report a problem with our site. 

The information you give us may include your name, title, addresses, e-mail address, date of birth and phone numbers, financial and credit card information, personal description and demographic information (such as preferences and interests). 

  • Information we collect about you. With regard to each of your visits to our website or use of our app(s) or WiFi Service the following information will be collected:
  • Technical Data including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system (including device) and platform and other technology on the devices you use to access this website.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. 

  • Usage data about your visit and how you use our products and services, including information about how you use our website, the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), page response times, timestamp marking at restaurant, download errors, customer session duration, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number. 
  • Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.
  • CCTV: Information provided through CCTV recordings at our restaurants for the purposes of security.
  • Information we receive from other sources (including third parties). This is information we receive about you if you use any of the other websites we operate or the other services we provide (including the WiFi Service in our restaurants). We are working closely with third parties (including, for example, business partners, our WiFi providers, sub-contractors in technical services, advertising networks, analytics providers, search information providers). 

We may receive personal data about you from various third parties and public sources including technical data from analytics providers such as Google based outside the EU or search information providers.

Minors. If you are a minor under 16 years of age, please obtain consent from your parent or guardian before you submit any personal information to us. If you are a parent or guardian of a minor and you have reason to believe your child or ward has provided us with their personal information without your prior consent, please contact us to request for erasure of their personal data or for the minor to be unsubscribed from our mailing lists.

Uses made of the information

We use information held about you in the following ways:

  • Information you give to us. We will use this information:
  • to administer our site and WiFi Service;
  • to obtain your feedback; 
  • to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
  • to manage our relationship with you, including your restaurant bookings; 
  • to provide you with information about other products and services we offer that are similar to those that you have already purchased or enquired about;
  • to provide you, or permit selected third parties to provide you, with information about products or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about products and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you are happy for us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data;
  • to notify you about changes to our service;
  • to administer and manage your account and associated services including updating your records;
  • to ensure that content from our site is presented in the most effective manner for you and for your computer or device. 
  • Information we collect about you. We will use this information:
  • to administer our site and WiFi Service and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to improve our site and WiFi Service to ensure that content is presented in the most effective manner for you and for your computer; 
  • to allow you to participate in interactive features of our service, when you choose to do so;
  • as part of our efforts to keep our site safe and secure;
  • to comply with laws and regulations that apply to us;
  • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
  • to make suggestions and recommendations to you and other users of our site about products or services that may interest you or them.
  • Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

Purposes for which we will use your personal data

We have set out below, in a table format, a description of ways we plan to use your personal data, and which of the legal bases we rely on to do so. 

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. 

Purpose/Activity Lawful basis for processing including basis of legitimate interest
To confirm a table booking Necessary for our legitimate interests
To provide you with access to our WiFi Service (a) Performance of a contract with you 

(b) Necessary for our legitimate interests

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Performance of a contract with you 

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey (a) Performance of a contract with you 

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and our website and app(s) (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)   (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website and app content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about services that may be of interest to you Necessary for our legitimate interests (to develop our products/services and grow our business)
CCTV in our restaurants (a) Necessary for our legitimate interests (for security, crime prevention and customer and staff safety)

(b) Necessary to comply with legal obligations

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us

We do not carry out automated decision making.

Disclosure of your personal data

We may share your personal data with the parties set out below:

  • Other companies in our Group, including those which provide IT and system administration services and undertake leadership reporting. 
  • External third parties including: 
  • service providers who provide IT and system administration services, social media networks, data management companies, digital agencies, reservation booking platforms, gift voucher solutions providers, and professional advisers, 
  • HM Revenue & Customs, regulators and other authorities;
  • business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.  This includes our WiFi providers for the purposes of the WiFi Service in our restaurants and business partners for the purpose of administering customer satisfaction surveys;
  • advertisers and advertising networks that require the data to select and serve relevant adverts to you and others; and
  • analytics and search engine providers that assist us in the improvement and optimisation of our site.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. 
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect our rights, property, or safety, or that of our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Where we store your personal data

We do sometimes transfer data outside the EEA but before doing so take steps to ensure that your data will be given adequate protection as required by the Data Protection Legislation.  We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. 

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any 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.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 

Your rights

You have the right to ask us not to process your personal data for marketing purposes. You can also exercise the right at any time by contacting us at contact@boparanrestaurants.com. 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 purposes. 

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.  Please check these policies before you submit any personal data to these websites.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. 

You also have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive details of the personal data we hold about you.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. 
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. This right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. 
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Cookies

Our website 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 website and also allows us to improve our site. 

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies: 

  • Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services. 
  • Analytical/performance cookies (e.g. traffic log cookies). They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. 
  • Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

We also use software called Google Analytics which is a web analytics service provided by Google Inc. in order to understand how visitors to our website use the site. The Google Analytics cookies remember you from one page request to the next, for example to differentiate between ‘new’ and ‘returning’ visitors. We receive reports from Google Inc. about website usage (such as the number of visitors to our site or the number of unique page views).

You can block and restrict cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. You may wish to visit www.aboutcookies.org, which contains comprehensive information on how to do this on a wide variety of desktop browsers. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

Important Information & Who We Are

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how Carluccio’s collects and processes your personal data through your use of our website, your use of our restaurants, your participation in a Carluccio’s event, or any data you may provide when you sign up to our newsletter, purchase a product or service or take part in a competition.

This website is not intended for children and we do not knowingly collect data relating to children. If you are under the age of 18, you should obtain your parents’ or guardians’ permission before you contact us – this is simply because of the nature of some of our products (such as alcohol) we have a legal obligation to check you are over 18.

CONTROLLER

Carluccio’s Limited is the controller and responsible for your personal data (referred to as “Carluccio’s”, “we”, “us” or “our” in this privacy notice).

We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

CONTACT DETAILS

You can contact our Data Privacy Manager at:

Carluccio’s Limited

Post: 12 Moor Street, London, W1D 5NG

FAO: Data Privacy Manager

Email Address: contact@boparanrestaurants.com

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on 30/11/2018 and historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

The Date We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, social media handles or account names.
  • Contact Data includes billing address, delivery address, email address, telephone numbers and emergency contact telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login 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 this website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services, including the purpose of your visit to our website and any information that you share regarding your visit to one of our restaurants.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or 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.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How Is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • buy or express an interest in our products or services, in one of our restaurants or on our website;
  • create an account on our website;
  • make a booking/reservation at one of our restaurants;
  • access our guest Wi-Fi;
  • enter into a transaction with us;
  • subscribe to our newsletter;
  • request that we send a brochure or product sample or other marketing materials to you;
  • enter a competition, promotion or survey;
  • provide feedback on any restaurant booking or speak to customer services more generally, by telephone, email, social media or any other form of messaging.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie notice for further details.

How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where we have your consent.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

You have the right to withdraw consent to marketing at any time by unsubscribing via the link provided with each marketing email we send to you or by contacting us using the contact forms on the website.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

 

Type of data

 

Lawful basis for processing including basis of legitimate interest

 

To register you as a new customer (a) Identity

(b) Contact

Performance of a contract with you
To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To confirm your reservation in one of our restaurants (a) Identity

(b) Contact

(a) Consent

(b) Performance of a contract with you

(c) Necessary for our legitimate interests (to ensure we are providing the expected level of customer service and to study how customers use our services)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy notice

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To manage our after sales relationship with you, including:

(a)    Assisting you with customer service issues

(b)    Contacting you in relation to a product recall

(c)     Requesting details and feedback of your visit to our restaurants

(a) Identity

(b) Contact

(c) Profile

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to ensure we are providing the expected level of customer service and to study how customers use our services)

To enable you to partake in a prize draw, competition or complete a survey (a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)(c) Consent

To respond to customer queries received on social media (a) Identity

(b) Contact

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to ensure we are providing the expected level of customer service)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you. We offer regular information concerning our menus, restaurants and services (a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(a) Necessary for our legitimate interests (to develop our products/services and grow our business); or

(b) Consent

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We will only contact you for marketing purposes via email if you have agreed to this, whether directly through us or via a third-party provider. If you don’t want to receive a newsletter, or any further promotions from Carluccio’s simply change your subscription status to “UNSUBSCRIBED” in the ‘Subscription’ area of the ‘My Account’ section of our website after you have logged in. Alternatively you may click the “unsubscribe” button from any emails you receive from us.

 

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (this is “marketing”).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing. You will also receive marketing communications from us if you have provided us with your details when you entered a competition or registered for a promotion and gave us your consent as part of that process. We may personalise our communications with you based on the information you provide to us and the information we obtain when you use our platforms.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any other company for marketing purposes.

 

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us.

Opting out of marketing messages will not prevent you receiving non-marketing messages from us, for example relating to products ordered from us, responses to customer service queries etc.

COOKIES

For more information about the cookies we use, please see our Cookies Notice. The following resource offers you simple guides on how to remove cookies from each browser. (Carluccio’s is not responsible for the content of third party websites).

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures Of Your Personal Data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • External Third Parties as set out in the Glossary.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International Transfers

We do not transfer your personal data outside the European Economic Area (EEA).

Some of our external third parties are based inside the USA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

Whilst not sharing your personal information, we may use suitable and accredited third-party organisations specifically for the purpose of destroying or deleting any personal data.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data Retention

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. We also keep this basic information about our customers for seven years following your most recent interaction with us, whether this is a purchase (to enable us to deal efficiently with any after-sales queries that you may have, or warranty/recall issues) or a marketing interaction. We keep customer profile information that you have indicated you are happy for us to have in order to keep you up to date regarding our products, services and events and will keep this information until such time as you indicate you no longer wish us to keep this data or, as a back-stop, six years following your most recent active interaction with us (e.g. clicking on an email link we send you, taking you to our site).

In some circumstances you can ask us to delete your data: see “Request erasure” in ’10. Glossary’ below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

If you wish to exercise any of the rights set out above, please contact us.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights), including identification such as a passport, driving licence or recent utility bill. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if we have not been able to confirm your identity, your request is particularly complex, or you have made a number of requests. In this case, we will notify you and keep you updated.

Cookies Notice

Our website (carluccios.com) 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 website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie type Source Name Purpose Expiry
Analytical/ performance carluccios.com _ga
_gat
_gid
ajs%3Acookies
ajs%3Atest
ajs_group_properties
ajs_user_traits
We use Google Analytics to understand how visitors use our website Expiry ranges from 1 day to persistent
Analytical/ performance carluccios.com ajs_anonymous_id To identify the number of visitors on the site 1 year
Analytical/ performance doubleclick.net r/collect To monitor visitors’ devices and behaviour on our site via Google Analytics Expiry
Analytical/ performance google-analytics.com Collect To monitor visitors’ devices and behaviour on our site via Google Analytics Session
Analytical/ performance carluccios.com _hjIncludedInSample To analyse visitors’ behaviour on our site Expiry
Targeting carluccios.com _gcl_au To monitor ad performance 3 months
Targeting google.com ads/ga-audiences For ad targeting Session
Targeting carluccios.com _fbp Used by Facebook for ad targeting 1 day
Targeting carluccios.com ajs_group_id To assign specific visitors in to segments, based on visitor behaviour on the website 1 year
Targeting carluccios.com ajs_user_id To collect data on the visitor’s behaviour and then assign them to a segment 3 months
Targeting facebook.com fr Used by Facebook for ad targeting Session
Targeting facebook.com tr Used by Facebook for ad targeting Session
Functionality twitter.com personalization_id Allows the visitor to share content from the website on his/her Twitter profile 2 years
Functionality sharethis.com     ab12# To share content to social networks 1 year
Functionality carluccios.com sharethis_cookie_test To share content to social networks Session
Functionality carluccios.com tld Unclassified 1 year
Functionality twitter.com i/adsct Used by Twitter to share content 9 months
Functionality carluccios.com unam Used to share content to social networks 1 year
Functionality carluccios.com stid Used to share content to social networks 1 month
Functionality carluccios.com CNL Controls the pop up newsletter subscribe form 1 day
Functionality carluccios.com CLastViewed To gather last viewed product data to recommend products to other users 2 years
Strictly necessary carluccios.com bigcommerce_cart_id To link the website to the cart 1 day
Strictly necessary carluccios.com bigcommerce_cart_item_c ount To keep track of how many items are in the users cart Session
Strictly necessary carluccios.com catAccCookies To record that you accept the fact that the site uses cookies Session
Strictly necessary carluccios.com wordpress_test_cookie Checks if cookies are enabled to provide appropriate user experience Session
Strictly necessary carluccios.com wordpress_logged_in* Checks whether or not the current visitor is logged in Session
Strictly necessary carluccios.com wp-settings* Sets various settings for logged in users 1 month

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Consent means you have explicitly given us permission to process your personal data. In such circumstances we will have asked you a specific question and you will have entered information or ticked a tick-box to indicate your consent.

THIRD PARTIES

  • Service providers acting as processors based in the UK who provide IT and system administration services.
  • Service providers acting as processors based in the UK who provide ecommerce home delivery services.
  • Service providers acting as processors based in the UK who provide gift card services.
  • Service providers acting as processors based in the EU and USA who provide ecommerce payment services
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
  • Email and display advertising service providers, acting as processors, based in the UK;

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. In such circumstances we may reserve the right to delete your personal data rather than hold it but restrict processing, where our processes are not set up to enable a restriction.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Request to opt out of automated profiling of your personal data. You have the legal right to opt-out of any automated profiling of your personal data that could have a legal consequence for you, and have a human being involved in the processing decision rather than it being automated. The only profiling of this type that we undertake is in our marketing activities, in which we tailor our marketing communications to your transactional history and product preferences.  If you wish to opt-out of this automated profiling please contact us, though please be aware that our systems are not configured to send un-tailored marketing communications to you, so in practice opting out of automated profiling will result in you being opted out of receiving marketing communications from us.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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