Privacy Policy

BACKGROUND

 

Tumbuka Cafés understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, (Tumbuka-cafes.com) and only collect and use your personal data as described in this Privacy Policy. Any personal data we collect will only be used as permitted by law.

 

Please read this Privacy Policy carefully and ensure that you understand it.

 

   1. Information About Us. 

Our Site is owned and operated by Tumbuka Cafés, a sole trader, Registered address: Gréjan, Rochegude, 30430, France. 

Email address: info@tumbuka-cafes.com.

Telephone number: +33 (0) 6 78 17 86 09.

Representative: Dominique Whitehead.

 

   2. What Does This Policy Cover?

This Privacy Policy applies only to your use of Our site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

 

   3. What Is Personal Data?

"Personal Data means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person." (iclg.com)

"The French Data Protection Act implements article 5 of the ePrivacy Directive. Pursuant to Article 5(3) of the EU ePrivacy Directive (Directive 2002/58/EC), amended in 2009, the storage of cookies (or other data) on an end user's device requires prior consent, unless this storage is necessary for the provision of an online communication service expressly requested by the user or is exclusively for the purpose of enabling or facilitating a communication by electronic means.

 

The CNIL recalled that such "consent" refers to the definition and condiUons set out in Articles 4(11) and 7 of the GDPR. Thus, it must be free, specific, informed and unambiguous, and the user must be able to withdraw it at any time, as easily it was given.

 

The CNIL has also adopted guidelines applicable to the deposit and reading of trackers in the user's terminal on 17 September 2020. They are supplemented by a recommendation which provides examples of practical ways of collecting consent." (iclg.com)

 

 

   4. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

    1. The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 10.

    2. The right to access the personal data we hold about you. Part 9 will tell you how to do this.

    3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 10 to find out more.

    4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 10 to find out more.

    5. The right to restrict (i.e. prevent) the processing of your personal data.

    6. The right to object to us using your personal data for a particular purpose or purposes.

    7. The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.

    8. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

    9. Rights relating to automated decision-making and profiling. We do not use your personal data in this way. 

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 10.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 10.

 

   2. What Personal Data Do You Collect and How?

Subject to the following, we do not collect any personal data from you. We do not place cookies on your computer or device, nor do we use any other means of data collection.

Our Site collects certain information automatically, including your IP address, the type of browser you are using, and certain other non-personal data about your computer or device such as your operating system type or version, and display resolution.

If you send us an email, we may collect your name, your email address, and any other information which you choose to give us. For the purposes of the Data Protection Legislation, We are the data controller responsible for such personal data.

 

   3. How Do You Use My Personal Data?

Where we collect any personal data, it will be processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under the Data Protection Legislation at all times. For more details on security see Part 7, below.

As stated above, we do not generally collect any personal data directly from you, but if you contact us and we obtain your personal details from your email, we may use them to respond to your email. The other technical data referred to above is necessary for the technical operation of Our Site [and will not normally be used in any way to personally identify you].

 

   4. How and Where Do You Store My Data?

[We will [only store your personal data] OR [store some of your personal data] within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.]

Personal data security is essential to us, and to protect personal data, we take the following measures:

  • limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;

  • procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we legally required to do so;

 

   5. Do You Share My Personal Data?

[We will not share any of your personal data with any third parties for any purposes, subject to the following exception[s].

[If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way that we have used it, as specified in this Privacy Policy (i.e. to communicate with you).]

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.]

 

   6. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”. This can be achieved with the link below our policy. 

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 10. [To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.]

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within less than one month. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

 

   7. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details : 

Email address: info@tumbuka-cafes.com.

Telephone number: +33 (0) 6 78 17 86 09.

   8. Changes to this Privacy Policy

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

 

Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on 18/07/2021.