PRIVACY POLICY

Version: Wednesday 24th November 2021

Introduction

Welcome to Victoria House Tearoom privacy & cookies notice.

Victoria House respects your privacy and is committed to protecting your personal data. This
privacy & cookies notice will inform you as to how we look after your personal data when
you visit our website www.victoriahousetearoom.com (the “Website”), regardless of where
you visit it from, or when you deal with us over the telephone (whether to order a product
or make an enquiry, or otherwise) and tell you about your privacy rights and how the law
protects you.

Please the Glossary to understand the meaning of some of the terms used in this privacy &
cookies notice.

1. Important information and who we are
2. The data we collect about you
3. How is your personal data collected?
4. How we use your personal data
5. Disclosures of your personal data
6. International transfers
7. Data security
8. Data retention
9. Your legal rights
10. Cookies Policy
11. Glossary

1. Important information and who we are

Purpose of this privacy & cookies notice

This privacy & cookies notice aims to give you information on how Victoria House Tearoom collects and processes your personal data through your use of our Website and/or contacting us over the telephone, including any data you may provide when you sign up to
our newsletter, purchase a product or service or take part in a competition.

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

It’s important that you read this privacy & cookies notice together with any other privacy &
cookies notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why
we are using your data. This privacy & cookies notice supplements the other notices and is not intended to override them.

Controller

Victoria House Tearoom Ltd is the controller and responsible for your personal data
(collectively referred to as "Victoria House Tearoom", "we", "us" or "our" in this privacy &
cookies notice).

If you have any questions about this privacy & cookies notice, including any requests to exercise your legal rights (as detailed below), please contact our Customer Service team using the details set out below.

Contact details

Our full details are:

Full name of legal entity: Victoria House Tearooms Ltd
Email address: vhtearoom@outlook.com
Postal address: Victoria House Tearoom, 2 Wargate Way, Gosberton. PE114NH
Telephone: 01775 841100

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.

Changes to the privacy & cookies notice and your duty to inform us of changes.

This version was last updated on Wednesday 24th November 2021.
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.

Third-party links
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 &
cookies notice of every website you visit.

2. The data 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 may collect, use, store and transfer different kinds of personal data about you which we
have grouped together follows:
• Identity Data includes first name, last name and title.
• Contact Data includes billing address, delivery address, email address and
telephone number.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other
details of products and services you have purchased from us.
• 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 our Website.
• Profile Data includes your username and password, purchases or orders made by
you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our Website, products and
services.
• Marketing and Communications Data includes your preferences in receiving
marketing from us and your communication preferences.

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. 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 & cookies
notice.

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.

If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform
the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with
us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:
• 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 otherwise. This
includes personal data you provide when you:
o apply for our products;
o create an account on our Website;
o request marketing to be sent to you;
o enter a competition, promotion or survey;
o give us some feedback; or
o make a complaint.

• Automated technologies or interactions. As you interact with our Website, we
may automatically collect Technical Data about your equipment, browsing actions
and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites after visiting our Website. This data enables us to place adverts about our products on those websites when you visit them. We obtain this data by employing
cookies on our Website. Please see our Cookies Policy below for further details.
• Third parties or publicly available sources. We may receive personal data about
you from various third parties as set out below:
o Technical Data from analytics providers based inside and outside the EU, for
example Google Analytics.
o Contact, Financial and Transaction Data from providers of technical, payment
and delivery services based inside and outside of the EU, for example Sage
Pay Europe Limited.
o Contact Data and Transaction Data from SMG, Trustpilot, (as referred to in
the definition of “External Parties” in the Glossary below).

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use
your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered
into with you.
• 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.
• Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other
than in relation to sending third party direct marketing communications to you via email or
text message.

If on occasion we do require your consent for any particular type of processing (for example
if you wish to divulge health information to us as part of a complaint or query), we will
ensure that we have obtained your Consent as required by law. You have the right to withdraw Consent at any time by contacting us.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control
mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on
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 (we call this marketing).
You will receive marketing communications from us if you have requested information from
us or purchased goods from us or if you provided us with your details when you entered a
competition or registered for a promotion and, in each case, you have not opted out of
receiving that marketing. We will obtain your consent and advise you of how to opt-out of
receiving such communications where we are required to do so in accordance with
applicable law.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any
company outside the Victoria House Tearooms & Taylors group of companies for marketing
purposes.

Opting out/Unsubscribing from Marketing

Opting out of email marketing:
You can ask us to stop sending you marketing messages by at any time by clicking here
or by contacting us at any time or by clicking on the “unsubscribe” link in any marketing emails that we send you.

Opting out of postal marketing (including catalogues/brochures):
You can ask us to stop sending you postal marketing at any time by contacting us.

Where you opt out of receiving these marketing messages and/materials, this will not apply to personal data
provided to us as a result of a product/service purchase, product/service experience or other transactions.

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 our Website may become inaccessible or not function properly. For more information

about the cookies we use, please see our Cookies Policy below or click on the “Cookies
Page” link on the Website.
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.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes
set out in the table in paragraph 4 above.
• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Specific third parties as set out in column 5 of the table in section 4 How we use
your personal data above.
• 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 & cookies notice.
• Government authorities, law enforcement and regulatory authorities where required
or permitted by law.
• External parties in response to legal process, and when required to comply with laws,
or to enforce our agreements, corporate policies, and terms of use, or to protect the
rights, property or safety of Victoria House Tearoom, our employees, agents,
customers, and others.
• Parties to whom you authorise Victoria HouseTearoom to release your personal
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.

6. International transfers

Some of our external third parties are based outside the UK so their processing of your
personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal 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 personal data to countries that have been deemed to
provide an adequate level of protection for personal data. For further details, see the
Information Commissioner's Office guidance on international transfers of data which
is accessible by clicking here.
• Where we use certain service providers, we may use specific contracts approved for
use in the UK which give personal data the same protection it has in the UK. For
further details, see European Commission: Model contracts for the transfer of
personal data to third countries, which is accessible by clicking here.
Please contact us if you want further information on the specific mechanism used by us
when transferring your personal data out of the UK.

7. 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.

8. Data retention

How long will you use my personal data for?
We will only retain 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.
Details of retention periods for different aspects of your personal data are set out in column
4 of the table in section 4 above entitled How we use your personal data.
By law we have to keep basic information about our customers (including Contact, Identity,
Financial and Transaction Data) for six years after they cease being customers for tax
purposes.
In some circumstances you can ask us to delete your data: see Request Erasure of your
Personal Data 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.

9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your
personal data. Please click on the links below to find out more about these rights:
• Request access to your personal data.
• Request correction of the personal data that we hold about you.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing of your personal data.

• Request the transfer of your personal data.
• Withdraw consent.

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

10. Cookies Policy
Like many websites, when you visit our Website or click on an advert of ours on another
website we issue 'cookies'. The following paragraphs give you information on the cookies
that we use on the Website and what we use them for.
What are cookies?
Cookies are small text files that websites send to your computer. They let the website know
when the user has returned. This allows the website to bring up information relevant to that

user, for example your name, past orders etc. Cookies only contain and transfer to the
website as much information as you have disclosed to the website, nothing else.
How do we use cookies?

We use cookies to note the different areas of our Website recently accessed through your
computer, which of our adverts you were interested in and to identify which websites and
adverts about us are of interest to you after you leave our website. We will use the
information collected in this way to tell you about services or products which might be of
interest to you when you make further visits to our Website, or through other websites from
which we provide advertisements.
What cookies do we use on the Website?

When you visit our Website, cookies are either sent directly by us, or by our third-party
service providers. Details of the categories of cookies we may use are as follows:
Preferences cookies: These cookies help website owners to understand how visitors
interact with websites by collecting and reporting information anonymously.
Necessary cookies: These cookies help make a website usable by enabling basic functions
like page navigation and access to secure areas of the website. The website cannot function
properly without these cookies.
Statistics cookies: These cookies help website owners to understand how visitors interact
with websites by collecting and reporting information anonymously.
Marketing cookies: These cookies are used to track visitors across websites. The intention
is to display ads that are relevant and engaging for the individual user and thereby more
valuable for publishers and third-party advertisers. This includes tracking visitors to social
media and displaying relevant and engaging ads on such platforms.
For full details of the cookies we use click on the “Cookies Page” link on the Website.
How can you opt-out of cookies from our Website?

Most web browsers automatically accept cookies, but your browser's settings can be altered
to prevent this. If you do this, you will not be able to shop from our Website as the
functions of the Website are dependent on cookies. In addition, Cookies can be deleted from
your hard-drive. How you do this will depend upon the Internet browser that you use.
Please refer to your relevant Internet browser manufacturer's website, where you should be
able to get the information you need. Please note that cookies are computer specific, so if
you log on to our Website from a different computer, the cookie settings on that computer
will apply.
For further information about managing and disabling cookies on your computer, see the
website www.allaboutcookies.org.
Find out how to manage cookies on popular browsers:
• Google Chrome
• Microsoft Edge
• Mozilla Firefox
• Microsoft Internet Explorer
• Opera
• Apple Safari
To opt out of being tracked by Google Analytics across all websites,
visit http://tools.google.com/dlpage/gaoptout.
Your consent to Cookies

We may need to ask for your consent to the use of cookies set out in this privacy & cookies
when you first access the Website and if we introduce any new cookies to the Website. If
so, when you first visit the Website a banner will appear asking you to accept the cookies
that we set on the Website.

If you agree to cookies from our Website by clicking on the button to confirm your
agreement, by actively closing the cookies banner, or by continuing to use the Website, we
will set cookies on your computer. If you wish to delete the cookies we have set on your
computer, please refer to your browser ‘Help’ menu.

11. Glossary
LAWFUL BASIS

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.

Consent: means obtaining your explicit, informed and freely given consent to the
processing of your personal data by an unambiguous statement or clear affirmative action
on your part.
THIRD PARTIES
(a) Internal Third Parties
Other companies in the Victoria House Tearoom acting as joint controllers or processors,
who are based in the UK and carry out management, analysis, planning and decision
making, including in relation to taking decisions regarding the expansion and promotion of
our product and service offering, order or customer request fulfilment, or provide IT and
system administration services.

(b) External Third Parties
• Service providers acting as processors based in the UK and the USA, who provide
logistics services, for example Federal Express Corporation. (Further details of how
Federal Express Corporation uses your personal data are set out below.)
• Service providers acting as processors based in the United Kingdom who may from
time to time provide call centre services.
• Service providers acting as processors based in the United Kingdom who provide IT
hosting and IT maintenance.
• Service providers acting as processors based in the United Kingdom who provide IT
and system administration services.
• Service providers acting as processors based in the United Kingdom, who provide
credit card processing services, for example Sage Pay Europe Ltd.
• Service providers acting as processors who provide customer review services –
Service Management Group Limited (based in the UK) and Trustpilot A/S (based in
Denmark).
• Professional advisers acting as processors or joint controllers including lawyers,
bankers, auditors and insurers based in the United Kingdom, who provide
consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or
joint controllers based in the United Kingdom, who require reporting of processing
activities in certain circumstances.
How our courier for non-EU deliveries will use your personal information
If you ask us to deliver any products to countries outside of the European Union, we will
transfer some of the personal information you provide to us to our courier Federal Express
Corporation (and/or its subsidiary companies) or such alternative courier as we may from
time to time appoint (in either case, “the Courier”), for the purposes of undertaking delivery
of such products to your chosen destination.
The categories of personal information that we will transfer to the Courier in such
circumstances are as follows:
• Recipient’s name;
• Recipient’s address;
• Recipient’s postcode;
• Your and/or recipient’s email address;
• Your and/or recipient’s telephone number.
If you do not provide us with this information, we may not be able to arrange for delivery of
the products you have ordered to your chosen destination. If this is the case, we will advise
you accordingly.

The personal data referred to above will be passed to the Courier and/or its affiliates located
in and/or outside of the European Economic Area, including in the United States, for the
purposes of delivering the products you have ordered in accordance with your instructions
and any alternative delivery instructions received from you subsequently.
YOUR LEGAL RIGHTS

You have the following legal rights:
(a) Request access 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.
(b) Request correction of the personal data that we hold about you
You have the right to 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.
(c) Request erasure of your personal data
You have the right to 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.
(d) Object to processing of your personal data
You have the right to 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.
(e) Request restriction of processing of your personal data
You have the right to 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: (a)
if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but
you do not want us to erase it; (c) 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; or (d) you have
objected to our use of your data but we need to verify whether we have overriding
legitimate grounds to use it.
(f) Request the transfer of your personal data
You have the right to 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.
(g) Withdraw consent
You have the right to withdraw your 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.