PRIVACY POLICY – USE OF PERSONAL INFORMATION

Use of personal data
1. Data Controller

Danish Bake UK Limited is data controller as further set out below.

2. Setting up and login into your user profile

In connection with setting up your user profile we will process the following personal data about you:

"Mobile number" with a view to set up a user profile and subsequent log-in.

The legal basis for our processing of your personal data in that context is the pursuit of our legitimate interest in accordance with the General Data Protection Regulations (“GDPR”) article 6, section 1 (f). Our legitimate interests amount to:

Being able to identify you with a view to setting up your user profile and subsequent log-in details for your user profile; and
Allocate a unique user-ID based on your mobile number.

You may additionally choose to provide certain personal data when you sign up. Such additional personal data will be processed in accordance with this Privacy Policy.

3. Loyalty program

When you sign up for our loyalty program and for the purpose of the subsequent administration of the rewards under the loyalty program we will process the following personal data about you for the following purposes (subject to your having provided such personal data to us):

“Name” in order to identify you in the store following placement of an order;
“Mobile number” in order to identify you and contact you, and for the purpose of identifying you to other users of our loyalty program / app, so they can give you a gift via the app.;
“E-mail address” in order to contact you including including but not limited to with regard to notifying you of changes to the loyalty program and its terms and conditions (subject to you having provided us with an email address for your user profile);
“Information regarding valid student ID” with regard to administrate any applicable student discounts;
“Date of birth” for verification purposes when dealing with customer related telephone calls;
“Allocated Vouchers” in order to administrate rewards and discounts under the loyalty program;
“Payment card information” in order to identify purchases with a view to record and show purchase history and administrate rewards under the loyalty program;
“Notifications” from a store you have made purchases in for the purpose of providing you with e.g. offers on products;
“Purchase History” including e.g. information about amounts paid, quantity and type of products purchased as well as the aggregated purchases (prior to bonus award). It will also include receipts for purchases (made in store and via App). This is relevant in order to administrate awards under the loyalty program including entitlement to free coffee etc. (“Bonus Coffee”) or bread etc. (“Bonus Purchases”) based on your previous purchases.

The legal basis for processing your personal data is either (1) article 6, section 1 (f) of the EU General Data Protection Regulation (“GDPR”) on the basis that our processing is necessary for the purpose of performing the contract which you have entered into with us or for the purpose of implementing measures requested by you prior to entering into our agreement, or (2) the pursuit of our legitimate interest in accordance with article 6, section 1 (f) of the GDPR. Our legitimate interests are to:

identify you as customer;
contact you in your capacity as a customer; and
administrate the loyalty program, including identification of purchases in order that we can manage your Purchase History and offer you such rewards, discounts and vouchers which you are entitled to under the loyalty program.

4. Targeted Marketing

By signing up to the Ole & Steen loyalty program you may give your consent to our processing personal data we hold about you to enable us to analyze which products and services you may be interested in, in order that we can send you relevant and customized offers, discounts, vouchers, newsletters, etc. to you on the basis of such analysis.

If you have provided us with the below personal data, we will process such personal data about you in connection with the abovementioned processing:

“Name”
“Date of Birth”
“Mobile number”
“Email address”
“Notification” from a store you have made purchases from
“Purchase History”

The legal basis for the abovementioned processing is article 6, section 1 (a) and (b) of the GDPR if you consent to such processing in a marketing context. You may withdraw your consent at any time by sending your mobile number to app@oleandsteen.co.uk as stated in clause 3.5 in the Terms and Conditions, or de-register your consent to targeted marketing.

Further, we also use “Notification” from a store you have made purchases from, your “Purchase History” and “Payment card information” for our employees in our stores to be able to give you offers, discounts, vouchers, etc. in connection with purchases made.

5. Online purchases

In connection with online ordering and purchasing of products (coffee, bread etc.) via the app, we may collect and process the following personal data about you:

“Name” for identification purposes and to effect purchases;
“Mobile number” in order to contact you in respect of collection of purchases and delivery of service notifications;
“E-mail address” in order to contact you with regard to collection of purchases;
“Information about valid student ID” in order to calculate applicable student discount;
“Geographical data” in order to place orders, purchases and collections in the store nearest to you;
“Payment card information” in order to effect purchases;
“Purchase History” in order to issue any applicable bonuses and discounts.

The legal basis for such processing is article 6, section 1 (b) of the GDPR on the basis that such processing is necessary to effect and fulfil the agreement you enter into with us, or for the purpose of implementing measures requested by you prior to entering into our agreement.

6. Product optimisation

We use the below personal data as part of (1) optimization of our product range, (2) for the purpose of developing new products and (3) in order to improve the application in order to optimize the user experience (e.g. repair errors and customization of software design). In connection with the above we may process the following personal data about you (subject to you having provided us with the below personal data):

“Notifications” from a store you have shopped in including but not limited to offers on products
“Purchase History” including amongst others information about including e.g. information about amounts paid, quantity and type of products purchased as well as the aggregated purchases (prior to bonus award) and used bonusses and discounts (free coffee and bread). It will also include receipts for purchases (made in store and via App).

The legal basis for such processing is that it is done in the pursuit of our legitimate interest in accordance with article 6, section 1 (f) of the GDPR. Our legitimate interest which is pursued by the processing is that we may obtain an understanding and insight into the potential opportunities for optimization and development of our application with regard to improving the customer experience.

7. Statistics

We will also convert the below personal data to statistics whereby the aggregated data (the statistical information) will be used to improve the application in order to optimize the user experience (e.g. repair errors and adapting software design). Additionally, we may use the statistical data in order to develop and improve stores, product range, offers and other commercial concepts which we offer to our customers.

If you have provided us with the below personal data, we will process such personal data about you in connection with the abovementioned processing:

“Date of birth”
“Information about valid student ID” in order to calculate applicable student discount;
“Issued Vouchers”
“Geographical data”
“Purchase History” including amongst others information about e.g. amounts paid, quantity and type of products purchased as well as the aggregated purchases (prior to bonus award) and used bonusses and discounts (free coffee and bread).

The legal basis for the conversion into statistics is based on the pursuit of our legitimate interest in accordance with article 6, section 1 (f) of the GDPR. The legitimate interests which are pursued by the processing are:

Improvement of the application with a view to optimize the user experience;
Development and improvement of stores, product range, offers and other commercial concepts.

8. Deletion of personal data

We will delete or anonymise all your personal data no later than 24 months after your last activity in the loyalty program, see also clause 6.6 in the Terms and Conditions. We will delete or anonymize your personal data as soon as possible and no later than 1 month after either the termination talking effect or the date you withdrew your consent if you terminate your membership of the loyalty program (and close your account) or withdraw your consent to our processing of your personal data.

We will however retain your personal data which relate to purchases of products and services to the extent such storing is required for accounting purposes (which is 6 years from the expiry of the relevant financial year the data relates to) after which period the personal data will be deleted or anonymized.

9. Your rights

According to the personal data legislation, you have certain rights in connection with our processing of your personal data. You may contact us in accordance with clause 11 in the Terms and Conditions, if you wish to enforce your rights.

Right to access to your personal data: You have a right to access the personal data which we hold about you;
Right to rectification (corrections): You are entitled to have incorrect or incomplete information about you corrected.
Right to request erasure of your personal data: In certain circumstances you have a right to have information about you erased before the end of the retention period.
Right to restrict processing: In certain circumstances, you have a right to restrict the processing of your personal data. If you have such a right, we may only process such data (except for storage) with your consent or in order to establish a legal entitlement or defend a legal entitlement or to protect a person or important matters of public interest.
Right to object: In certain circumstances you have a right to object against our otherwise legal processing of your personal data.
Right to transfer personal data (data portability): In certain circumstances you have a right to receive your personal data in a structured, commonly used and machine-readable format and to have transferred such personal data by a data controller to a third party without obstruction.

You may find further information about your rights in ICO guidance which you will find on https://ico.org.uk/. In addition, you may at any time withdraw your consent (see clause 3.5 in the Terms and Conditions) (however this will not affect the lawfulness of any processing carried out before your withdrawal).

We will process all requests as soon as possible and in accordance with applicable law.

10. Categories of recipients

The following categories of recipients will in the context of processing your personal data receive your personal data:

Data processers such as IT providers who deliver technical solutions to Ole & Steen in order that the application may be fully functioning
Related Group companies

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

11. Security

We implement adequate technical and organizational measures in accordance with article 32 of the GDPR in order to ensure a level of security which adequately covers the risk associated with the processing activities such as accidental and or illegal destruction, loss, alteration or unauthorized disclosure of or access to personal data which is transmitted, stored or in other ways processed and which specifically may lead to physical, material or immaterial damage taking into consideration the actual technical level, implementation costs and the relevant processing activity, extent, context and purpose as well as the risks of varying probability and seriousness for the customers rights and freedoms.

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.

12. Cookies

We use cookies on our website and our App, and we exchange cookies with third parties Facebook, Microsoft, Pinterest, Instagram, Youtube and/or Google. Cookies are small text files, which are saved on your device when you use our app/website. Cookies are harmless and do not contain virus. We use cookies to improve your experience when using our App. Further, Facebook, Instagram, Microsoft, Pinterest, Youtube and/or Google provide cookies, which are used for statistics and marketing.