Sunbaba Systems Limited

Last updated: 28 March 2022

  1. ABOUT THIS PRIVACY AND COOKIES NOTICE

The website www.sunbaba.co.uk (the Site) is operated by Sunbaba Systems Limited (“we”, “us”, “our”), a company incorporated in England and Wales under company number 2255302. Our registered office is at Sunbaba House, Newmarket, Suffolk, CB89XA.

  1. CONTACT INFORMATION

    • If you have any concerns or would like further information about our use of data or this notice in general, you can contact Jonathan Booth at jb@sunbaba.co.uk or on 02089889100.
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  2. WHAT INFORMATION DO WE COLLECT?

    • We collect, store and use the types of personal data set out in the table at the end of this notice.
  3. HOW WILL WE USE YOUR PERSONAL DATA?

    • We will use your personal data for the purposes set out in the table at the end of this notice.
  4. HOW DO WE SHARE YOUR PERSONAL DATA?

    • When we share personal data, we do so in accordance with Data Protection Law. We may share certain personal data, where necessary, with employees, contractors, consultants or advisers, to facilitate sales and for general commercial purposes.
    • We may also provide third parties with aggregated but anonymised information and analytics about our customers. Before we do so we will make sure that it does not identify you.
  5. USE OF COOKIES AND SIMILAR TECHNOLOGIES

    • We and our third-party service providers use cookies and similar technologies to collect information about, and relevant to, your usage of the Site. Cookies are small text files that are stored on your computer when you visit the Site. It is standard practice to use cookies to make your experience better when using a website.
    • We use the following categories of cookies and similar technologies on this Site:
      • Strictly necessary cookies: These cookies are essential to enable you to move around the Site and use its features, and to keep the Site secure. Without these cookies, services you have asked for (such as remembering your login details or the items you placed in your basket) cannot be provided.
      • Analytics cookies: These cookies collect information about how you use the Site, for instance which pages you go to most often, what searches you perform and if you get error messages from web pages. Information these cookies collect can be used to improve how the Site works.
    • When you visit the Site for the first time (and periodically after that), we will request your consent to the setting of all cookies other than strictly necessary cookies.
    • You can delete existing cookies and disable some or all types of cookies in future if you wish. To disable some or all types of cookies, you will have to either change the settings on your browser or use the cookie manager tool on the Site. See https://www.allaboutcookies.org/manage-cookies/ for information on how to change your browser settings. If you change your mind, you can enable cookies again at any time. Disabling cookies on your browser may stop the Site from working properly.
    • To find out more about cookies please visit allaboutcookies.org.
  6. THIRD PARTY LINKS

    • This Site may contain links to other websites over which we have no control. We are not responsible for and do not review or endorse the privacy policies or practices of other websites which you choose to access from this Site. We encourage you to review the privacy policies of those other websites, so you can understand how they collect, use and share your personal information.
  7. YOUR RIGHTS

    • We respect your rights to privacy and will respond to requests for access or control over information about you in accordance with Data Protection Law. We may require you to verify your identity before we take any action.
    • Depending on the reason we have your personal data, you have a right to:
      • access the personal information we hold about you (commonly known as subject access);
      • request that we correct or complete personal information we hold about you that is inaccurate or incomplete;
      • request that we erase your personal information in some circumstances, or object to our processing it as detailed at paragraph 8.5;
      • restrict how we use your personal information, in certain circumstances;
      • request that we provide you with copies of your personal information in a machine-readable format or transfer it across different services; and
      • where we have asked for your consent to process your data, to withdraw this consent.
    • These rights are limited in some situations under Data Protection Law – for example, where we can demonstrate that we are under a legal obligation to process your data. If you wish to exercise any of these rights, please contact us using the details in paragraph 2 above.
    • Your right to object
      • You have a right to object to our processing of your personal data and ask us to stop doing so. If we are processing your personal data for direct marketing purposes (which includes profiling to the extent that it is related to such direct marketing) and you object to this, we will stop processing your personal data immediately.
      • If our processing of your personal data is in the public interest or pursuant to our legitimate interests and you object to this, we will stop processing your personal data unless we have compelling reasons which override your interests, or our use of your personal data is for the establishment, exercise or defence of legal claims.
      • We hope that we can satisfy any queries you may have about the way we process your data. However, if you have unresolved concerns you also have the right to complain to data protection authorities (in the UK, the Information Commissioner’s Office). You can call the ICO on 0303 123 1113 or go to their website: https://ico.org.uk/make-a-complaint/).
  1. DATA RETENTION

    • Your personal data will only be kept for as long as necessary for our purposes. Specific retention periods are set out in the table at the end of this notice.
    • At the end of the specified retention periods, your personal data will either be securely destroyed or anonymised, unless we are required to keep it to comply with our legal obligations.
  2. DATA PROTECTION PRINCIPLES

    • We process your personal data in accordance with the following principles:
      • we process your personal data lawfully, fairly and in a transparent way;
      • we collect your personal data for specified, explicit and legitimate purposes; any further processing we do is compatible with the original purposes for which we collected it;
      • we only process personal data that is adequate, relevant and limited to what is necessary to achieve the purpose for which it is processed;
      • we take reasonable steps to ensure that all personal data is accurate and kept up to date where necessary;
      • we do not store personal data in a form that identifies you for any longer than is necessary for the purposes of our processing; and
      • we process personal data securely and in a way that protects against unauthorised or unlawful processing, accidental loss, destruction or damage.
    • When we ask for your personal data we will tell you whether you are required by law or contract to provide it, and what will happen if you do not provide the data.
    • Any request for consent to the processing of your personal data will be made directly to you and will include information about why we require the personal data and what will be done with it.
  3. WHAT IS OUR LAWFUL BASIS FOR PROCESSING?

    • We will only process personal data when we have a lawful basis for doing that processing. The table at the end of this notice sets out the lawful basis we rely on for each type of data we process.
    • We will choose one of the lawful bases in the UK GDPR to justify how we use your personal data. These are:
      • Consent: You have given consent to the processing of your personal data for one or more specific purposes. You have the right to withdraw your consent at any time, as detailed in paragraph 8.2.
      • Contract: The processing is necessary for the performance of a contract with you or to take steps at your request before entering into a contract.
      • Legal obligation: We need to process your personal data to comply with a legal obligation.
      • Vital interests: The processing is necessary to protect the vital interests of you or another person.
      • Public interest: Processing is necessary for the performance of a task carried out in the public interest or in the exercise of some official authority.
      • Legitimate interests: Processing is necessary for the purposes of legitimate interests pursued by us or someone else, except where such interests are overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.
  1. ATTRIBUTION

    • This privacy and cookies notice was created using a template from Sparqa Legal (https://www.sparqa.com), March 28, 2022.

 

 

 

 

TABLE OF PERSONAL INFORMATION WE USE

 

The table below sets out detailed information about the types of personal information we collect, our purposes for processing, the basis for processing and the retention period for the personal data.

 

Category of personal data

 

Purpose of processing

 

Lawful basis for processing

 

Retention period

 

Name and contact details

 

To deliver your purchases to you

To send you order updates

For fraud prevention and detection

 

 

 

Performance of contract

 

 

 

 

For three years since you last logged on to the Site

 

 

 

Purchase history

 

To provide customer service and support and handle future enquiries

 

 

 

Performance of contract

 

 

 

For six years after purchase

 

 

Browser, device and Site usage information

 

To improve the Site

To protect the Site against fraud

To set default options for you, such as language and currency

 

Performance of contract

 

Legitimate interest in maintaining our Site

For three years since you last logged on to the Site

 

Customer comments and product reviews

 

To improve our products and services

Where relevant, to establish, exercise or defend legal claims

Performance of contract

 

Legitimate interest in dealing with complaints or claims and improving our products and/or services generally

 

For six years

 

Information collected through cookies and similar technologies

To conduct and store Site usage analytics, statistical and trend analysis and market research

To generate customer profiles to facilitate marketing initiatives

 

Consent

For three years since you gave consent, or until you withdraw consent if earlier