PURPOSE OF OUR POLICY

1. The Happy Prawn Co., a brand of The Happy Seafood Co. Limited (Company Number 9256974) (we, us or our) provides the products and services offered on the website (www.thehappyprawn.co) (Website).  
2. For the purposes of the Data Protection Act 1998 (Act), we are the data controller. This policy takes into account application in the European Union of the General Data Protection Regulation (GDPR) from 25 May 2018.
3. We have adopted this Privacy Policy to ensure that we have standards in place to protect the data that we collect about individuals that is necessary and incidental to:
   1. Providing the products and services that we offer; and
   2. The normal day-to-day operations of our business.
4. By publishing this Privacy Policy, we aim to make it easy for our users, customers and the public to understand what data we collect and store, why we do so, how we receive and/or obtain that information, and the rights an individual has with respect to their data in our possession.

WHO AND WHAT THIS POLICY APPLIES TO

1. We handle data in our own right and also for and on behalf of our customers and users.
2. The Privacy Policy applies to all forms of information, physical and digital, whether collected or stored electronically or in hardcopy.
3. If, at any time, an individual provides data or other information about someone other than himself or herself, the individual warrants that they have that person's consent to provide such information for the purpose specified.

THE INFORMATION WE COLLECT

1. In the course of business it is necessary for us to collect data. This information allows us to identify who an individual is for the purposes of our business, share data when asked of us, contact the individual in the ordinary course of business and transact with the individual.  Without limitation, the type of information we may collect is:
   1. Personal Information.  We may collect personal details such as an individual’s name, location, date of birth, nationality, family details and other information that allows us to identify who the individual is;
   2. Contact Information.  We may collect information such as an individual’s email address, telephone & fax number, third-party usernames, residential, business and postal address and other information that allows us to contact the individual;
   3. Financial Information.  We may collect financial information related to an individual such as any bank or credit card details used to transact with us and other information that allows us to transact with the individual and/or provide them with our services;
   4. Digital / Device Information. We may collect your IP address and device-specific information, such as the hardware model, operating system version, advertising identifier, unique application identifiers, unique device identifiers, browser type, language, wireless network, and mobile network information (including the mobile phone number); 
   5. Statistical Information.  We may collect information about an individual’s online and offline preferences, habits, movements, trends, decisions, associations, memberships, finances, purchases and other information for statistical purposes; and
   6. Information an individual sends us.  We may collect any personal correspondence that an individual sends us, or that is sent to us by others about the individual’s activities, including activities with our partners (such as Facebook or Twitter).
2. We may collect other data about an individual, which we will maintain in accordance with this Privacy Policy.
3. We may also collect non-data about an individual, such as information regarding their computer, network and browser.  This may include their IP address. 

HOW INFORMATION IS COLLECTED

1. Most information will be collected in association with an individual’s use of the Website, products and services, an enquiry about the Website or generally dealing with us.  However, we may also receive data from other sources such as advertising, an individual’s own promotions, public records, mailing lists, contractors, staff, recruitment agencies and our business partners (such as Facebook or Twitter).  In particular, information is likely to be collected as follows:
   1. Registrations/Subscriptions/Purchases.  When an individual registers, subscribes and or purchases a product, service, list, account, connection or other process whereby they enter data details or grant access to information in order to receive or access something, including a transaction or services;
   2. Accounts/Memberships.  When an individual submits their details to open an account and/or become a member with us;
   3. Partners.  When an individual grants us access to their accounts with our business partners (such as Facebook or Twitter).
   4. Supply.  When an individual supplies us with goods or services;
   5. Contact.  When an individual contacts us in any way;
   6. Access.  When an individual accesses us physically, we may require them to provide us with details for us to permit them such access;
   7. Cookies/Pixel Tags. Cookies and pixel tags enable us respectively to analyse your use of website and send email messages in a format customers can read and they tell us whether mail has been opened.
2. As there are many circumstances in which we may collect information both electronically and physically, we will endeavour to ensure that an individual is always aware of when their data is being collected.
3. We may also collect anonymous data such as traffic, IP addresses and transaction statistics, which may be used and shared on an aggregated and anonymous basis. 

HOW DATA IS STORED

1. The data that we collect from you will be stored in the European Economic Area (EEA), but may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services.  
2. Data may also be processed by third parties and/or staff operating outside the EEA who work for us or for one of our third party partners. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. 
3. We will retain data for the period necessary to fulfil the purposes outlined in this policy unless a longer retention period is required or permitted by law.
4. By submitting your personal data, you agree to this transfer, storing or processing. 

WHEN DATA IS USED & DISCLOSED

1. In general, the primary principle is that we will not use any data other than for the purpose for which it was collected other than with the individual’s permission.  The purpose of collection is determined by the circumstances in which the information was collected and/or submitted.
2. We will retain data for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.
3. It may be necessary for us to disclose an individual’s data to third parties in a manner compliant with the Act in the course of our business.
4. We will not disclose or sell an individual’s data to unrelated third parties under any circumstances.
5. Information is used to enable us to operate our business, especially as it relates to an individual.  This may include:
   1. The provision of goods and services between an individual and us;
   2. Verifying an individual’s identity;
   3. Communicating with an individual about:
      1. Their relationship with us;
      2. Our goods and services;
      3. Our own marketing and promotions to customers and prospects;
      4. Competitions, surveys and questionnaires;
   4. Investigating any complaints about or made by an individual, or if we have reason to suspect that an individual is in breach of any of our terms and conditions or that an individual is or has been otherwise engaged in any unlawful activity; and/or 
   5. As required or permitted by any law (including the Act). 
6. There are some circumstances in which we must disclose an individual’s information:
   1. Where we reasonably believe that an individual may be engaged in fraudulent, deceptive or unlawful activity that a governmental authority should be made aware of;
   2. As required by any law (including the Act); and/or
   3. In order to sell our business (as we may transfer data to a new owner).
7. We will not disclose an individual’s data to any entity outside of the United Kingdom that is in a jurisdiction that does not have a similar regime to the Act or an implemented and enforceable privacy policy similar to this Privacy Policy. We will take reasonable steps to ensure that any disclosure to an entity outside of the United Kingdom will not be made until that entity has agreed in writing with us to safeguard data as we do.
8. We may partner with or utilise third-party service providers to communicate with an individual and to store contact details about an individual. These service providers may be located outside the United Kingdom, including the United States of America.

THIRD PARTY ACCOUNTS

1. We may link your account with a third party (such as Facebook or Twitter) to our services to enable certain functionality, which allows us to obtain information from those accounts (including your profile picture, friends or contacts). 
2. The information we may obtain from those services often depends on your settings or their privacy policies.

COOKIE POLICY

1. Our Website uses cookies to distinguish you from other users of our platform. This helps us to provide you with a good experience when you browse our platform and also allows us to improve our Website. By continuing to browse the site, you are agreeing to our use of cookies.
2. 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 to the terms of this policy. Cookies contain information that is transferred to your computer's hard drive.  You 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.
3. Please refer to our Cookie Policy for further information.

OPTING “IN” OR “OUT”

1. An individual may opt to not have us collect their data.  This may prevent us from offering them some or all of our services and may terminate their access to some or all of the services they access with or through us.  They will be aware of this when:
   1. Opt In.  Where relevant, the individual will have the right to choose to have information collected and/or receive information from us; or
   2. Opt Out.  Where relevant, the individual will have the right to choose to exclude himself or herself from some or all collection of information and/or receiving information from us.
2. If an individual believes that they have received information from us that they did not opt in or out to receive, they should contact us on the details below. 

THE SAFETY & SECURITY OF DATA

1. We will take all reasonable precautions to protect an individual’s data from unauthorised access.  This includes appropriately securing our physical facilities and electronic networks.
2. The security of online transactions and the security of communications sent by electronic means or by post cannot be guaranteed.  Each individual that provides information to us via the internet or by post does so at their own risk.  We cannot accept responsibility for misuse or loss of, or unauthorised access to, data where the security of information is not within our control.
3. We are not responsible for the privacy or security practices of any third party (including third parties that we are permitted to disclose an individual’s data to in accordance with this policy or any applicable laws).  The collection and use of an individual’s information by such third parties may be subject to separate privacy and security policies.
4. If an individual suspects any misuse or loss of, or unauthorised access to, their data, they should let us know immediately.  
5. We are not liable for any loss, damage or claim arising out of another person’s use of the data where we were authorised to provide that person with the data.

HOW TO ACCESS AND/OR UPDATE INFORMATION

1. The Act gives you the right to request from us the data that we have about you. 
2. If an individual cannot update his or her own information, we will correct any errors in the data we hold about an individual within 7 days of receiving written notice from them about those errors.
3. It is an individual’s responsibility to provide us with accurate and truthful data. We cannot be liable for any information that is provided to us that is incorrect.
4. We may charge an individual a reasonable fee for our costs incurred in meeting any of their requests to disclose the data we hold about them if such a request is manifestly unfounded or excessive. We reserve the right to clarify the specific information your request relates to.
5. Information will be provided within one month of receipt of the request.

COMPLAINTS AND DISPUTES

1. You have the right to object to:
   1. processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);
   2. direct marketing; and
   3. processing for purposes of scientific/historical research and statistics.

   unless we hold legitimate grounds for processing or the processing is for the establishment, exercise or defence of legal claims.

2. If an individual has a complaint about our handling of their data, they should address their complaint in writing to the details below.
3. You have the right to lodge a complaint with a supervisory authority if you consider that the processing of your data infringes the GDPR. 
4. If we have a dispute regarding an individual’s data, we both must first attempt to resolve the issue directly between us.
5. If we become aware of any unauthorised access to an individual’s data, which is likely to result in a high risk for the rights and freedoms of the data subjects we will inform the individual without undue delay after becoming aware of it once we have established what was accessed and how it was accessed.

ADDITIONS TO THIS POLICY

1. If we decide to change this Privacy Policy, we will post the changes on our website. It is your responsibility to refer back to this Privacy Policy to review any amendments.
2. We may do things in addition to what is stated in this Privacy Policy to comply with the Act and nothing in this Privacy Policy shall deem us to have not complied with the Act.

CONTACTING US

1. All correspondence with regards to privacy should be addressed to:

   The Data Controller
   The Happy Prawn Co.
   info@thehappyprawn.co

   You may contact us by email in the first instance.