To download a pdf version of our privacy notice click here.
WHO WE ARE
This privacy notice is issued on behalf of Panku Streetfood which is a brand created and owned by Taiko Foods Ltd. Taiko Foods Ltd is part of the Snowfox Group and are incorporated under SnowFox Midco 1 Limited in England and Wales, company number 09846773. Our registered office address is 34-40 Brunel Road, Acton, London, England, W3 7XR. So when we mention “we”, “us” or “our” in this policy, we are referring to the relevant company in the Snowfox Group responsible for processing your data.
Snowfox Group is the controller and responsible for this website. We respect your privacy and are committed to protecting your personal information and are registered with the Information Commissioner’s Office, registration number ZB287652. For more information about the Snowfox Group please click here.
This notice will inform you how we look after your personal data. We also use this privacy notice to tell you about your privacy rights and how the law protects you.
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.
Changes to the privacy notice
We keep our privacy notice under regular review. We may change this Notice from time to time. Please check this Notice on our Website regularly to ensure you are aware of the most recent version.
INFORMATION WE COLLECT
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 permanently removed (anonymous data).
The information we collect, use, store and transfer depends on whether you have signed you up to our newsletter or whether you are just browsing our website.
The data we collect can be grouped together as follows:
• Contact Data email address, again only if you sign up to our newsletter or provide it to us when you review our products
• Technical Data includes internet protocol (IP) address, 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
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences
• Usage Data includes information about how you use our website and URLs visited, this will be dependent on what cookies you have consented to
Special categories of personal information
We do not process any sensitive personal data of website users.
HOW WE COLLECT YOUR DATA
We use different methods to collect data from you including through:
• Direct interactions. You may give us your Identity and Contact Data by filling in “Subscribe to Newsletter” form or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
o enquire about our products
o request marketing to be sent to you
o give us feedback or contact us
• Third parties such as Facebook, Instagram and Twitter.
HOW YOUR DATA IS USED
In simple terms we use your data when you complete the “Subscribe to Newsletter” form to hear all the latest news, views, offers, competitions and menu information.
Alternatively we may use your visit and movement around our website to assess the effectiveness of the website.
The table below details specifically how we may use your data when you are Website Visitor:
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer and provide you with our newsletter as requested when you complete the “Subscribe to Newsletter” form
|To manage our relationship with you which will include notifying you about changes to our terms or privacy notice||(a) Contact
|Necessary for our legitimate interests (to keep our records updated)|
|Information when customers communicate with us whether in person, through our website, via email, over the phone, through social media or via any other medium. We use this to:
(a) Answer any of your issues or concerns
(b) Monitor customer communications for quality and training purposes
|Necessary for our legitimate interests (to develop our business and to understand what customers think of our products)|
|To make suggestions and recommendations to you about services that may be of interest to you||(a) Identity
(c) Marketing and Communications
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, and system maintenance)||(a) Technical||Necessary for our legitimate interests (for running our business, provision of website and network security)
|To use data analytics to improve our website, marketing and user experiences||(a) Identity
|Necessary for our legitimate interests (to develop our business and to inform our marketing strategy)|
|Information that we collect incidentally from other sources or public sources, including information presented on our social media platforms, to:
(a) Maintain market awareness
(b) Build and maintain social media branding
|(a) Marketing and Communications||Necessary for our legitimate interests (to develop our products/services and grow our business)|
Third-party marketing – we will not share your data with any third parties for the purposes of direct marketing.
Opting out – you can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.
Change of purpose – Your data will only be used 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 at email@example.com.
If we need to use your data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
While our website is designed for a general audience, we will not knowingly collect information of children under the age of 13, and in some jurisdictions the personal information of children under the age 16.
If you believe we might have any personal information from or about a person under the age of 13 (or under the age of 16 in some jurisdictions), please email us at firstname.lastname@example.org.
WHO WE SHARE YOUR DATA WITH
Your data may be transferred to other third party organisations in certain scenarios:
- ● if we discuss selling or transferring part or all of our business – the information may be transferred to prospective purchasers under suitable terms as to confidentiality
● if we are reorganised or sold, information may be transferred to a buyer who can continue to provide services to you
● if we’re required to by law, or under any regulatory code or practice we follow, or if we are asked by any public or regulatory authority – for example the Police
● if we are defending a legal claim your information may be transferred as required in connection with defending such claim
In all cases we ensure that we have appropriate technical and organisational measures in place to protect your data to the highest standard.
TRANSFERRING DATA OUTSIDE THE UK
Most of our data processing takes place within the UK, however we employ some services which are based outside of the UK. In these cases, limited personal data is passed to another country (e.g. USA).
Whenever we transfer your data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- ● We will only transfer your data to countries that have been deemed to provide an adequate level of protection for personal data under the UK adequacy regulations. For further details, see Information Commissioner’s Office (ICO):
- Adequacy of the protection of personal data in non-UK countries.
- ● Where we use certain service providers, we may use specific contracts approved by the European Commission and amended by the ICO which give personal data the same protection it has in the UK. For further details, see ICO’s: Model contracts for the transfer of personal data to third countries.
- ● In the absence of an adequacy decision or appropriate contractual safeguards we may rely on derogations for specific situations. For further details, see GDPR Article 49: Derogations for specific situations.
Please contact us at email@example.com if you want further information on the specific mechanism used by us when transferring your data out of the UK.
SECURITY MEASURES TO PROTECT YOUR DATA
We have put in place appropriate security measures to prevent your data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your data on our instructions, and they are subject to a duty of confidentiality.
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.
HOW LONG WILL WE USE YOUR DATA
We will only retain your data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for your data, we consider the amount, nature and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure of your data, the purposes for which we process your data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data, see below “Exercising your rights”.
Sometimes we will anonymise your 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.
EXERCISING YOUR RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. 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:
- • If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful, but you do not want us to erase it.
• 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.
• 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. 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.
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.
If you wish to exercise any of the rights set out above, please contact us using firstname.lastname@example.org.
Individuals have a right to access personal data held about them. Should an individual whose data we store pursuant to our service agreement with our franchise partner, approach us to seek access, correction, amendment, or deletion of inaccurate data, we will ask them to direct their query to the franchise partner, the controller of such information. Then it will be up to the franchise partner to fulfil your request and we will assist as required.
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 could 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). 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.
Subject Access Request as a Service (SARaaS)
We are committed to providing the information you request as part of your Data Subject Access Request and have procedures in place to ensure this occurs in a timely fashion.
We do not have agreements in place with any third-party platforms that offer “Subject Access Requests as a Service”. As a responsible data controller of your personal information this represents significant risks when sharing data. The right of access afforded to you, does not obligate us to share data with third-parties. It is our policy to provide the information directly to data subjects ensuring the safety and security of the information throughout the process.
We will monitor future guidance from the Information Commissioner’s Office but will follow our reasonable measures to verify the identity of data subjects. We would like to assure you that the protection of your data is our main concern and we are committed to providing information as part of any valid request.
This policy will also apply to the rights set out above.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
CONTACT US OR MAKE A COMPLAINT
If you have any questions about this privacy notice or our privacy practices, please contact us at email@example.com.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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.