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Introduction
Protecting your data, privacy and personal information is very important to Momeo [insert legal entity name, e.g. “Momeo Ltd”] (“us”, “our” or “we”).
This policy (together with our Terms & Conditions and any other documents referred to in it), sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by Momeo.
Please read this privacy policy carefully to understand the types of information we collect from you, how we use that information, the circumstances under which we will share it with third parties, and your rights in relation to the personal data you provide to us.
Our Website contains links to third party websites. If you follow a link to any of those third party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal information.
Information We May Collect
Information that you provide to us
You will be asked to provide us with your information when you:
- —fill in forms on our Website, or correspond with us by phone, email or otherwise;
- —register to use our Services, subscribe to our newsletter, promotional emails or other marketing materials;
- —use the Services, including placing orders or customising products;
- —report a problem with our Services; or
- —complete any surveys we ask you to fill in that we use for research purposes.
The information you will be asked to provide includes your first name, surname, email address, phone number, delivery address, payment information, or further information required to verify your identity.
Information we collect about you automatically
- —Device-specific information, such as your hardware model, operating system version, unique device identifiers, and mobile network information.
- —Technical information about your computer, including your IP address, operating system and browser type.
- —Details of your visits to our Website, including the full URL clickstream, length of visits to certain pages, and page interaction information.
- —Information collected via cookies and similar technologies (see the Cookies section below).
Information we receive from other sources
When using our Services, we may receive information about you from third parties, including payment processors, delivery partners, and advertising platforms, in order to enable your use of the Services.
How We Use Your Information
Use of personal information under UK data protection laws must be justified under one of a number of legal grounds. These are the principal grounds that justify our use of your information: consent, contract performance, legal obligation, legitimate interests, and legal claims.
We use information held about you in the following ways:
| Types of Information | How We Use It | Basis |
|---|---|---|
| Name, email, address | Provide access to our Website and Services | Contract performance |
| Name, email, address, order details | Process and fulfil your orders, handle support | Contract performance |
| Name, email | Marketing our own products and services | Legitimate interest |
| Name, email, order details | Improve and personalise our Services | Legitimate interest |
| Email address | Notify you about changes to our Services | Contract performance / legitimate interest |
We will not sell your personal data to third parties; however, we reserve the right to share any data which has been anonymised and/or aggregated.
Advertising Partners
We share information with a number of trusted advertising partners including but not limited to Google and Facebook (Meta) to enable us to deliver targeted advertising to you.
[Momeo should list all advertising partners here, or link to a regularly updated page of partners.]
For more information on making informed choices about online advertising, visit: youradchoices.com
Marketing
We may use your information for marketing our own products and services to you. Where required by law, we will ask for your consent at the time we collect your data.
We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you, or you may opt out by contacting us at hello@momeo.co.uk.
Where We Store Your Personal Information
The personal data that we collect from you is processed in the European Economic Area (“EEA”) and/or the United Kingdom and stored on [specify cloud hosting providers, e.g. “Amazon Web Services (Europe)”] cloud servers.
Countries outside the EEA/UK may not provide the same level of adequate protection for the rights and freedoms of data subjects. In such cases, we shall only transfer your data where:
- —the destination country has a valid adequacy decision from the UK Secretary of State or European Commission;
- —we have ensured appropriate safeguards have been put in place (such as International Data Transfer Agreements or standard contractual clauses); or
- —another lawful transfer mechanism applies under applicable data protection law.
Your passwords are stored on our servers in encrypted form. Although Momeo will do its best to protect your personal data, we cannot guarantee the security of data transmitted to our Website — any transmission is at your own risk.
A full list of our third party sub-processors can be found at [insert link to sub-processor list].
Disclosure of Your Information
We may disclose your personal information to third parties in the following circumstances:
- —To our service providers and business partners, including manufacturers, payment processors, and delivery partners, to provide the Website and Services.
- —If we sell or buy any business or assets, to the prospective seller or buyer of such business or assets.
- —If we are under a duty to disclose or share your personal data to comply with any legal obligation.
- —For fraud prevention and other checks. If false or inaccurate information is provided and fraud is identified, details may be passed to fraud prevention agencies.
- —To courts, regulators or law enforcement agencies where compelled to do so.
How Long We Retain Your Personal Data
We will hold the above information for as long as is necessary in order to provide you with the Services, deal with any specific issues that may arise, or otherwise as is required by law or any relevant regulatory body.
Once your account is terminated or deactivated, we shall delete the personal data relating to your account within 30 days. If your account is inactive for 18 months, we may contact you to assess whether you want to continue to use the Services.
Some personal data may need to be retained for longer to ensure Momeo can comply with applicable laws, including retaining your email address for marketing suppression if you have opted out of marketing.
Your Rights
Under the UK GDPR and the Data Protection Act 2018, you have various rights in relation to your personal data. All of these rights can be exercised by contacting us at hello@momeo.co.uk.
| Right | Details |
|---|---|
| Right of Access | You have the right to obtain confirmation of whether personal data concerning you is being processed, and a copy of that data. |
| Right to Rectification | You may request correction of inaccurate or incomplete personal data. |
| Right to Erasure | You may ask us to delete your personal data. We will do so without undue delay unless there is a legitimate legal reason to retain it. |
| Right to Restriction | You have the right to ask us to stop processing your personal data at any time. |
| Right to Data Portability | You may request a copy of your data in a structured, commonly used and machine-readable format. |
| Right to Object | You have the right to object to processing based on legitimate interests, including for direct marketing. |
| Right to Complain | You have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk. |
We will not ordinarily charge you for exercising your rights; however, if you make excessive or manifestly unfounded requests, we may charge an administration fee or refuse to act.
Changes to This Policy
Any changes we make to our privacy policy in the future will be posted on this page, and where appropriate, notified to you by email. We encourage you to review it from time to time to stay informed of how we are processing your information.
Contact
Questions, comments and requests regarding this privacy policy are welcome and should be addressed to hello@momeo.co.uk.
For the purpose of the relevant data protection legislation, the data controller is [insert full legal entity name] (company no. [insert company number]) with registered address at [insert registered address].
Questions about this policy?
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