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Our Privacy Policy

Welcome to our privacy policy. We respect your privacy and are committed to protecting your personal data. 


1. Introduction


This privacy policy tells you how we use your personal data when you visit our website, interact with us, and buy goods through us. 


It also tells you about your privacy rights and how the law protects you.


It is important that you read this privacy policy, together with any other privacy policies we may provide, so that you are fully aware of how and why we are using your data.


This privacy policy was last updated on 21st of May 2018. 


If you have any questions, or would like to exercise your privacy rights, please follow the steps outlined below for you in this privacy policy. 


2. Our Website 


This website – our website – is owned by The Room Service Collection Ltd. Our details are as follows: The Room Service Collection Ltd, Company No: 10982014, Address: 9 Esplanade Gardens, Southsea, Hampshire, PO4 9LZ, Email: hello@theroomservice.co. 


We are a marketplace website and are the commercial agent of the ‘Makers’ featured on our website. We do not possess any items offered for sale by these makers but market their products and process orders for them.  


This website is not intended for children and we do not knowingly collect data relating to children.


3. Personal Data Which 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 collect a variety of information about our customers and visitors to our website. This personal data falls into these categories:


Identity Data includes title, first name, last name, username or similar identifier and an encrypted version of your login/password. If you interact with us through social media, this may include your social media user name.


Contact Data includes billing address, delivery address, email address and telephone numbers.


Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.


Profile Data includes your username and password, purchases or orders made by you, preferences, feedback and survey responses, as well as any profile data which we have added (for example, using analytics and profiling).


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.


Usage Data includes information about how you use our website, products and services.


Tracking Data includes information we or others collect about you from cookies and similar tracking technologies, such as web beacons, pixels, and mobile identifiers.


Marketing and Communications Data includes your preferences in receiving direct marketing from us and our third parties and your communication preferences.


As all of our payments are processed through paypal.com, we do not collect or hold any of your financial data. 


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. To provide better content and service, we use the Google Analytics service which records mouse actions and scrolling movement, as well as basic interactions with website forms but none of this contains personal data about you. Please see their privacy policy here. 


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 policy.


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. 


Remember, if you choose not to share personal data with us, or refuse certain contact permissions, we might not be able to provide the products and services you’ve asked for.


4. How Do We Collect Your Personal Data?


We collect data from and about you in a number of ways, including:


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 through chat or social media.


This includes personal data you provide when you:


sign up to receive our newsletter;


make enquiries or request information be sent to you;


create an account on our website;


order products through us;


ask for marketing to be sent to you;


engage with us on social media;


enter a competition, promotion or survey;


contact customer services; or


leave comments or reviews on our products or services.


Automated technologies or interactions. As you interact with us, including via our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may also collect Tracking Data when you use our website, or when you click on one of our adverts (including those shown on third party websites).


Third parties or publicly available sources. We may receive personal data about you from various types of third parties, including:


Technical Data and/or Tracking Data from analytics providers, advertising networks and search information providers;


Contact, Financial and Transaction Data from providers of payment and fraud prevention services;


Identity and Contact Data from data partners; and


Data from any third parties who are permitted by law or have your permission to share your personal data with us, such as via social media or review sites We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the circumstances detailed below. 


5.  How We Use Your Personal Data


Where we need to perform the contract we are about to enter into or have entered into with you. For example, when you purchase our products, that’s a contract.


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. For example, when we carry out fraud screening as part of the check-out process.


Where we need to comply with a legal or regulatory obligation. For example, keeping records of our sales for tax compliance.


Generally, we do not rely on consent as a legal basis for processing your personal data other than where the law requires it, for example in relation to sending certain direct marketing communications. Where our legal basis is consent, you have the right to withdraw consent any time.


The next section explains the types of lawful basis that we will rely on to process your personal data.


6. An Explanation of The Legal Bases We Rely Upon To Process Personal Data


The table below shows you a description of all the ways we plan to use 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.


We do not carry out any automated decision making.


If you ever have any questions about this, all you have to do is ask, just contact us as detailed below. 


Purpose/ActivityType of data 

Lawful basis for processing including basis of legitimate interest


To register you as a new customer (a) Identity 

(b) Contact 

(c) Profile


Performance of a contract with you.
To process and deliver your order, including: managing payments, fees and charges; and managing your queries through our Customer Service team – this may include recording calls to our teams. (a) Identity 

(b) Contact

(c) Financial 

(d) Transaction 

(e) Marketing and Communications


Performance of a contract with you. We may also use some of the data related to your queries for our legitimate interests of ensuring our customer service quality standards are met.
To collect and recover money owed to us in respect of your order(a) Identity 

(b) Contact 

(c) Financial 

(d) Transaction


Necessary for our legitimate interests (to recover debts due to us).
To carry out fraud assessments(a) Identity 

(b) Contact 

(c) Financial 

(d) Transaction

(e) Technical


Necessary for our legitimate interests of ensuring payments are not fraudulent
To process your purchase of a gift voucher from us(a) Identity 

(b) Contact 

(c) Financial 

(d) Transaction


Performance of a contract with you.
To notify you in relation to our legal obligations and documents, including changes to our terms or Privacy Policy(a) Identity 

(b) Contact 

(c) Profile


Necessary for our legitimate interests of ensuring our customers are updated on these changes.
To help us improve our offering to our customers, including asking you to leave a review or take a survey, or provide customer insights(a) Identity 

(b) Contact 

(c) Profile 

(d) Marketing and Communications


Necessary for our legitimate interests (to study how customers use our products/services, to improve our offering to our customers, to develop them and grow our business).
To enable you to partake in a prize draw or competition(a) Identity 

(b) Contact 

(c) Profile 

(d) Usage 

(e) Marketing and Communications


Performance of a contract with you to fulfil the promotion and run the competition/prize draw. We may also subsequently use your entries for the legitimate interests of understanding our customer base more effectively.
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) Profile

(d) Technical


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).
To deliver relevant website content, advertisements and other marketing material 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 to inform our marketing strategy and to improve our offering to you). Please note that where cookies are used for this purpose, this is covered separately by our Cookies Policy.
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). Please note that where cookies are used for this purpose, this is covered by our Cookies Policy.


To make suggestions and recommendations to you about goods or services that may be of interest to you(a) Identity 

(b) Contact 

(c) Technical 

(d) Usage 

(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business, and to improve our offering to you).

7. 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.


8. Advertising, Marketing and Your Communication Preferences


We may use your Identity, Contact, Technical, Tracking, Usage and Profile Data to form a picture of 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 and tell you about them. This is what we call direct marketing.


We may carry out direct marketing by email, phone, text or post. For example, you might have the newsletter pop into your inbox or a promotion land on your door mat.


We generally only send electronic marketing – such as email marketing – to people who have previously bought similar products from us or asked us to keep in touch with them and this is in our legitimate interests. We will always offer a way out of receiving this marketing when you first purchase our products and in every marketing communication afterwards. 


Where you have not previously bought from us but have registered your details with us (for example by entering a competition or signing up for a newsletter), we will only send you marketing communications if you opted into receiving marketing at the time and so given us your express consent – which you may withdraw at any time. 


On our website, we always try hard to make it really clear what we are doing and what communications you will be sent, whether it’s you deciding to sign up to our newsletter or as part of creating an account or the purchase journey – and you have a right at any time to change your mind and say no thank you and opt out. 


That said, we’d be really sorry to see you go, so please gives us a chance by fine tuning your preferences before really leaving us! 


The easiest way to opt out is to use the unsubscribe link at the bottom of any of the communications from us.


Of course, there are lots of different ways you’ll see adverts for The Room Service out and about, and not all of these are based on using personal data – sometimes we just buy good old-fashioned advertising space in the real world and websites and social media. If you see our adverts on websites and in social media, these may not be directed specifically at you, we might just have bid for the space. 


But here’s some things we may do that may be specifically directed at you:


emails, for example our newsletter;


text messages, for example with discount codes;


promotions by post, such as great money off shipping offers, or from our trusted retail partners; and/or


phone calls, to tell you something that might be relevant to you and your business.


We may use Tracking Data to deliver relevant online advertising, including via websites and social media. Tracking Data, and in particular cookies, helps us to deliver website and social advertising that we believe is most relevant to you and to potential new customers. The cookies used for this purpose are often placed on our website by specialist organisations. This includes retargeting. 


Cookies can also tell us if you have seen a specific advert, and how long it has been since you have seen it. This is helpful, because it means we can control the effectiveness of our adverts and control the number of times people might be shown our adverts. Cookies also help us understand if you’ve opened a marketing email because we don’t want to send you things you don’t read. If you want more information about Cookies, see Cookies below. 


Almost all the cookies that relate to advertising are part of third party online advertising networks. If you’d like to read about how you can control which adverts you see online, see opt-out programs established by the European Interactive Digital Advertising Alliancethe Digital Advertising Alliance. We do not control cookies which are set by advertising networks.


9. 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 or by contacting us at any time.


If you opt out of receiving email marketing from us, we will no longer share your email address with social media platforms, however you may continue to see our ads through them, due to their general demographic targeting. Please check the social media platforms for more detail of how to opt out from seeing these ads.


Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, or related correspondence, and we will continue to process such data in accordance with this Privacy Policy and only ever as permitted by law.


10. Cookies


You can see from Advertising, Marketing and Your Communications Preferences above, that cookies are a tool which we (and everyone one else who operates online) uses for advertising. That is just part of why cookies are used. Generally, they are pretty clever.


A cookie is a small text file which is downloaded and stored on your computer or mobile device by websites that you visit. (Where cookie technology is not available, an anonymous identifier may be used; this is a random string of characters used for the same purposes as a cookie). Your browser accesses the cookie file only when you visit the website that generated it. This helps to ease your navigation by automatically logging you in and remembering things like your preferences and what’s in your shopping basket.The information stored within any given cookie can only be accessed by the website that created it and cookies are limited to communicating only  the information that you have disclosed to the site.


Cookies help us work better and provide lots of help in the background to make the process of being one of our customers a lot easier. You’d miss a lot of these things if they were gone – like it being easy to log in and move from page to page, and things staying in your cart while you go off and look at other pages. 


Other cookies collect information about how visitors use our website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and we use it to improve how our website works.


There are also cookies that allow us to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. They may also be used to provide services you have asked for such as watching a video or commenting on a blog.


There are cookies that collect information about your browsing habits in order to make advertising delivered to you more relevant to you and your interests (see Advertising, Marketing and Your Communication Preferences above). They are usually placed by advertising networks with our permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.


By visiting our website with your browser settings adjusted to allow cookies, you are consenting to us using cookies for the purposes outlined below in order to provide you with a fully functional shopping experience.


We use the following types of cookie:


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 invoice services.


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.


You can see more information about the cookies we use here, including who they belong to, their ID and why they are used.


When you use our website, your device or browser may be sent cookies from third parties, for example when using embedded content and social network links. It’s important for you to know that we have no access to or control over cookies used by these companies or third-party websites. We suggest you check the third-party websites for more information about their cookies and how to manage them.


You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly, such as adding products to your basket or buying them. If you want to manage or disable cookies, you can use your browser to do this; each browser is different but the following links may help you: Google Chrome, Internet Explorer, Mozilla Firefox, Safari, Opera, Google Analytics Opt Out.


11. Disclosure Of Your Personal Data


We may share your personal data with the parties set out below for the purposes set out in this privacy policy. We may also share your personal data if the law otherwise allows it:


Suppliers and service providers, such as technology service providers, payment processing and fraud prevention providers, manufacturers and post and courier services;


auditors and professional advisers like bankers, lawyers, accountants and insurers; 


Our Makers to enable them to fulfil and despatch your orders; 


We may also share data with 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 policy.


We also share data with third parties connected to advertising, retargeting and analytics. Please see Advertising, Marketing and Your Communication Preferences and Cookies above for more information about who those third parties are; and 


government, regulators and law enforcement.


The lawful bases for sharing and processing this data is set out in the table above and please refer to the list of Third Parties listed in the Glossary below for further information.


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.


12. Payment Information


We use third party payment processor PayPal.com to process payments made for products through our Website. All online payments will be conducted through them and in accordance with Payment Card Industry (PCI) data security standards and your billing information (which is only used by these payment processors for the purpose of performing fraud protection) is encrypted before being communicated to them. Your credit card details are communicated directly from your browser to these payment processors and we never (ever!) see your card details and full Permanent Account Number (PAN). This means that the payment form is either off-site or displayed in a frame on the payment page. We only store the Paypal tokens required to identify the transaction with PayPal, issue refunds and identify transactions made using PayPal.


13. International Transfers


Whenever we transfer your personal data out of the EEA, we will comply with applicable data protection law. Some of the mechanisms we may choose to use when undertaking an international transfer are:


The transfer of your personal data is to a country that has officially been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.


We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe (called the “EU Model Clauses”). For further details, see European Commission: Model contracts for the transfer of personal data to third countries.


Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. If the provider is not EU-US Privacy Shield certified, we may use the EU Model Clauses. For further details, see European Commission: EU-US Privacy Shield.


Many of our external third-party providers are based outside the EEA, so their processing of your personal data will involve a transfer of data outside the EEA.


14. 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.


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.


You acknowledge that the Internet is not a completely secure medium for communication and, accordingly, we cannot guarantee the security of any information you send to us (or we send to you) via the Internet. We are not responsible for any damages which you, or others, may suffer as a result of the loss of confidentiality of such information.


15. Third-Party Links


This website may include links to third-party websites, plug-ins and applications (for example, the ability to share something you like on Pinterest). 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 policy of every website you visit.


16. Data Retention


We will only keep 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 stop being customers for tax purposes.


We also make a promise to you that you can come back at any time in the future and re-print products you have ordered from us in the past. So, unless you actively delete this information, we keep it, so we can keep our promise to you.


In some circumstances you can ask us to delete your data; see Your Legal Rights 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.


17. Your Legal Rights


If the General Data Protection Regulation applies to you because you are in the European Union, you have the following rights under data protection laws in relation to your personal data:


The right to be informed – that’s an obligation on us to inform you how we use your personal data (and that’s what we’re doing that in this privacy policy);


The right of access – that’s a right to make what’s known as a ‘data subject access request’ for copy of the personal data we hold about you;


The right to rectification – that’s a right to make us correct personal data about you that may be incomplete or inaccurate;


The right to erasure – that’s also known as the ‘right to be forgotten’ where in certain circumstances you can ask us to delete the personal data we have about you (unless there’s an overriding legal reason we need to keep it);


The right to restrict processing – that’s a right for you in certain circumstances to ask us to suspend processing personal data;


The right to data portability – that’s a right for you to ask us for a copy of your personal data in a common format (for example, a .csv file);


The right to object – that’s a right for you to object to us processing your personal data (for example, if you object to us processing your data for direct marketing); and


Rights in relation to automated decision making and profiling – that’s a right you have for us to be transparent about any profiling we do, or any automated decision making.


These rights are subject to certain rules around when you can exercise them. You can see a lot more information on them, if you are interested, on the UK Information Commissioner’s Office website.


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


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 or we may refuse to comply with your request in these circumstances.


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.


We try to respond to all legitimate requests within one month. Occasionally it may 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.


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


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.


18. How To Contact Us About Privacy


If you have any questions about this privacy policy, or would like to exercise any of your rights, please email us at hello@theroomservice.co or write to us at our registered address: The Room Service Collection Ltd, 9 Esplanade Gardens, Southsea, PO4 9LZ. 


 19. A Request From Us To You


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. You can do this by updating your account. Thank you.


20. Changes To This Privacy Policy


The General Data Protection Regulation is new and the ICO is still issuing new advice and guidance about how businesses should follow it. So, you may see some updates to our privacy policy over the coming months. We will email our customers to notify them of significant changes but please also check in and have read every now and then. Thank you.


21. Glossary


The following definitions are to help you make sure you fully understand the terms used above:


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.


External Third Parties include, but are not limited to the following:


Makers – when you place an order, we share your information with the relevant seller on our marketplace (“Maker”) so that they can process and deliver your order.


Email service providers – in order to send you marketing content and transactional emails, we share your details with our email service providers.


Social Media Platforms – We may make your name and email address available to companies in order to advertise and market our services to you through other platforms on the internet (e.g. Facebook). See the ‘Marketing’ section of this Privacy Policy above.


Analytics tools – we use analytics tools to track the way that users interact with our website.


Profiling tools – we use profiling tools to understand how you engage with our website and show you content we think will be most relevant to you, based on our understanding of your interests and preferences.


Payment providers – in order to facilitate any payments made on our site, we facilitate the sharing of your Financial Data with payment providers.


Delivery providers – in order to package and mail your orders to you, it is necessary to share your information with delivery providers.


Marketing and insights providers – marketing and insights tools allow us to understand our customers better so that we may provide you with the best possible website, products and customer service experience. We may share certain information about our customers to facilitate this process.


Customer service platforms – when you interact with our customer service team, your details are shared with our customer service platform providers.


Feedback forms – when you make a purchase, we engage a third party to send out feedback forms on our behalf.


22. Thank You.


Thank you for taking the time to read our Privacy Policy and – as outlined above – please just get in touch if you are unsure of anything or need some help.


The Room Service