Data Protection
Welcome to the website of Simple box. In our capacity as controller within the meaning of the General Data Protection Regulation, we are obliged to comply with statutory provisions on data protection. As a matter of course, we greatly value the protection of your personal data along with fair and transparent data processing. We have provided you below with all the information you need to verify and exercise your data protection rights.
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1. Who is responsible for data processing?
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The responsible party is:
Simple box E-Services UK LTD
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2. How can I contact the data protection officer?
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You can contact our data protection officer at:
Simple box E-Services UK LTD
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3. Why and on what legal basis do we process personal data?
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If you are a Simple box customer, create an account with us, participate in competitions or promotions or otherwise contact us, we will receive your personal data. We collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Security of Your Personal Information
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Simple box ensures that all information collected will be safely and securely stored.
We protect your personal information by:
- Restricting access to personal information
- Maintaining technology products to prevent unauthorised computer access
- Securely destroying your personal information when it's no longer needed for our record retention purposes
Identity Data
may include first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data
may include billing address, delivery address, email address and telephone numbers.
Financial Data
may include bank account and payment card details.
Transaction Data
may include details about payments to and from you and other details of products and services you have purchased from us.
Technical Data
may include 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.
Profile Data
may include your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data
may include information about how you use our website, products and services.
Marketing and Communications Data
may include your preferences in receiving marketing from us and our third parties 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 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.
We generally process data on the following legal bases:
- 6.1a GDPR, if you give us your explicit consent for data processing, e.g. if you are a prospective customer we may need your consent to send you marketing emails;
- 6.1b GDPR, if we are acting to fulfil our contractual obligations, e.g. if we use your email address to confirm the delivery date for your next cooking box;
- 6.1c GDPR, if we are acting to fulfil legal obligations, e.g. if we check your age and your identity before the conclusion of a contract, to prevent fraud, if you purchase alcohol as part of an order with us, or if you are to receive a free alcohol sample as part of a promotion;
- 6.1f GDPR, if we process your data due to a legitimate interest of ours or a third party’s, e.g. if we use your email address to send you our newsletter for direct advertising purposes, where we provide your data to third parties (as outlined below) or for optimizing our website’s advertising design.
3.1 Data processing by Simple box
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3.1.1 Shipping your cooking boxes / customer account
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We are pleased to be able to supply you with our food boxes and products. To enable you to order from us, we will create a customer account for you after your registration. In order to protect your customer account from access by third parties, we store your user name and password. In order to be able to deliver the food boxes to you as desired, we store your contact data, order and delivery time and payment information. You can voluntarily provide your phone number so that we can contact you in case of delays or problems delivering your food box. Please note that you may deactivate your account at any time.
3.1.2 Paying for the Simple box
Your payment details will be sent to the appropriate payment service provider depending on the payment method you choose. The payment service provider is responsible for your payment data. Information, particularly about the authority responsible for the respective payment service provider, the contact information for the data protection officers of the payment service providers and the categories of personal data that are processed by the payment service providers, can be obtained from the following addresses:
- PayPal (Europe) S.à.r.l. et Cie., Luxembourg, Data protection declaration: paypal.com/de/webapps/mpp/ua/privacy-full
- Adyen B.V. Netherlands, Data protection declaration: adyen.com/policies-and-disclaimer/privacy-policy
- American Express Services Europe Ltd., United Kingdom, Data protection declaration:americanexpress.com/uk/legal/european-implementing-principles.html
You authorise us to charge each payment to the payment card you use to make your initial payment. You will be able to view, amend, update and delete your payment card details when logged into your Simple box account using our virtual wallet service. You will be able to store multiple payment cards in your virtual wallet and choose which payment card to use for payment. If we are unable to complete a charge using your chosen payment card, you authorise us to charge a payment to any other payment card stored in your virtual wallet.
3.1.3 Customer Care
You can contact us via email, phone, chat or facebook message to ask us questions, send us messages or make complaints. We only process your personal data in this context in order to get in contact with you the way you wish and to answer or fulfil your request or complaint.
We may also use your personal data, such as your name, email address, phone number and product information to identify and call you to find out more about your experience with Simple box and how you think it could be improved. We may also call you or contact you via SMS after you have deactivated your customer account so that we can find out if you would like to re-activate it (or change how you have used Simple box’s services in the past). We may also send you reminders via SMS when one of your payment cards is close to expiry, your payment failed or in relation to other transactional matters. All of our calls will be recorded for training and monitoring purposes and you will have the right to opt out from receiving these calls or SMS at any time by contacting us at chef.kozakis@gmail.com or by informing the agent on the call.
3.1.4 Participation in competitions
If you take part in one of our competitions, we collect data that is necessary to carry out the competition. This usually includes an individual competition entry (e.g. a comment or a photo), as well as your name and your contact details. It is possible that we transmit this data to our competition partners, e.g. to send you the prize. The processing and transfer of data may vary depending on the competition and is therefore specifically described in the respective conditions of participation. Participation in the competition and the associated data collection is, of course, voluntary.
3.1.5 Comments on our blog
You have the option of leaving comments on our blog. Your comment, details at the time of writing the comment, email address and - if you do not post anonymously - username will be stored for the comment function on our web pages. Your IP address is also stored. Storage is necessary for us to be able to defend ourselves against liability claims in cases of possible publication of illegal content.
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3.1.6 Sending our newsletter
At Simple box, you have the option of subscribing to our newsletter in different ways, e.g. when registering or on our blog.
Advertising information will only be sent to your email address as part of our newsletter if you are an existing customer or have agreed to use your email address for this purpose. Of course, you can revoke your consent to be sent newsletters at any time, e.g. by clicking the unsubscribe link in the newsletter, updating the communication setting in your customer account or by sending a message to chef.kozakis@gmail.com.
3.1.7 Other advertising by Simple box
Simple box uses the email address, telephone number and postal address provided by the customer to inform on similar product and service offers by email, SMS and mail. If you do not wish to receive any further advertising information by email, SMS or mail, you can object to the use of your contact data for advertising purposes at any time without incurring any costs other than for transmission according to the basic rates.
You can submit your revocation by phone in our phone numbers, in writing at our address or emil us at chef.kozakis@gmail.com
If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this.
3.1.8 Social media
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Registration with Facebook Connect
We offer you the opportunity to register with us through Facebook Connect (Facebook Inc., USA, Data protection declaration: www.facebook.com/policy.php). An additional registration is not necessary in this case. You will be redirected to the Facebook page where you can log in with your user data. This will link your Facebook profile and our service. The link automatically provides us with the following information from Facebook: Facebook name, Facebook profile and cover picture, email address stored on Facebook, Facebook friends lists, Facebook likes, birthday, gender, country, language.
Data is used to set up, provide and personalize your customer account.
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3.2 Will my usage data be processed for website optimization and usage-based online advertising?
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Simple box uses cookies to create pseudonymous user profiles in compliance with legal requirements, but also to make the use of our website as optimal as possible. We can evaluate usage profiles in order to understand the use of our website, to determine target audiences for our products and to optimize our offers. When we create pseudonymous user profiles, we do not directly associate this data with you and therefore cannot trace specific activities back to you.
Cookies are small text files that are placed on your computer when you visit our website and allow your browser to be reassigned. Cookies store information such as your language setting, the duration of your visit to our website or the information you enter there. This avoids the need to re-enter all necessary data for each use. Cookies also enable us to recognize your preferences and to tailor our website to your interests.
Most browsers automatically accept cookies. If you want to prevent cookies from being saved, select “do not accept cookies” in the browser settings. You can find out how this works in detail from your browser provider’s instructions. You can delete cookies that are already stored on your computer at any time. However, we would like to point out that our website may only be of limited use without cookies. Alternatively, you can prevent the collection and forwarding of your data (particularly your IP address) and the processing of this data by deactivating the execution of Java Script in your browser or by installing a tool such as “NoScript.”
You can also disable the use of cookies by third parties by using the Network Advertising Initiative’s disabling tool. However, we and the providers will continue to receive statistical information on how many users visited our website and when.
We would like to explain some of the services in more detail below:
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3.2.1 Google Analytics
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Our website uses Google Analytics, a service of Google Inc., USA (“Google”). Google Analytics enables us to evaluate your website use in order to compile analyses of website activity and make use of other services associated with website and Internet use.
We would like to point out that the code “gat.anonymizeIp();” has been added to Google Analytics to ensure anonymous collection of IP addresses (so-called IP masking). Your IP address will be anonymised by Google within member states of the European Union or in other signatory states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the US and shortened there. The IP address transmitted by your browser with Google Analytics will not be merged with other Google data. More information on terms of use and data protection can be found at https://www.google.com/analytics/terms/de.html and https://www.google.de/intl/de/policies/.
In addition, you can prevent Google from collecting data by downloading and installing the browser add-on. By clicking the following link, an opt-out cookie is set that will prevent the future collection of your data when you visit this website: Disabling Google Analytics.
We also use the Google Conversion Tracking service as part of Google Analytics. This enables us to record the behavior of our website visitors. For example, we are shown how often the contact form has been filled in. We also see how many clicks on advertisements from external sources (AdWords, LinkedIn, Xing, Bing) have led to our website.
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4 Will my data be transmitted to third parties?
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In order for Simple box to process your data according to the purposes described above, it may be necessary for other recipients to also be able to view and process your data.
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4.1 Other service providers, partners and third parties
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Simple box shares personal data with third party service providers processing personal data on Simple box’s behalf in accordance with Art. 28 GDPR. This includes the following service providers, partners or third parties:
- Transport companies (for example, to ship and deliver your recipe box)
- Banks and payment service providers (for example, to process credit cards and payments)
- IT service providers (for example, to host, manage and service our data)
- Marketing companies who assist us with marketing campaigns
Simple box also shares personal data with third parties to the extent necessary to: (i) comply with a government request, a court order or applicable law (this includes age verification services provided through our partner Age Checked, if you purchase alcohol from us, or if you are to receive a free alcohol sample as part of a promotion); (ii) prevent illegal uses of our sites and apps or violations of our sites’ and the apps’ terms of use and our policies; (iii) defend ourselves against third party claims; and (iv) assist in fraud prevention or investigation (e.g., counterfeiting).
5 Will my data be processed outside the EU/EEA and how is data protection ensured?
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It is important to us to process your data within the EU/EEA. However, we may use service providers who process data outside the EU/EEA. In these cases, we ensure that an appropriate level of data protection is established prior to the transfer of your personal data. This means that a level of data protection comparable to the standards within the EU is achieved using EU standard contracts or an adequacy resolution such as the EU Privacy Shield.
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6 How long will my data be stored?
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We delete personal data as soon as the purpose of storage no longer applies and legal retention periods do not preclude deletion.
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 cease being customers for tax purposes.
At Simple box, we usually delete data as follows:
- Contract data: after termination of the Simple box subscription, except where retention obligations provide otherwise
- Contact requests: after processing the request
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7 Data Security
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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.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
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8 What rights do I have and how can I assert them?
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Every customer or any other person affected by data processing has the right to information according to Art. 15 GDPR, the right to correction according to Art. 16 GDPR, the right to deletion according to Art. 17 GDPR, the right to restriction of processing according to Art.18 GDPR, the right to objection according to Art. 21 GDPR and the right to data transferability according to Art. 20 GDPR.
You can revoke your consent to the processing of personal data at any time. This also applies to the revocation of declarations of consent that were given to us prior to the validity of the General Data Protection Regulation, i.e. before May 25, 2018. Please note that revocation will only take effect for the future. Processing that took place before the revocation is not affected.
You can submit your objection by email (chef.kozakis@gmail.com), or in writing.
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.
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.
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 under www.hellofresh.co.uk/contact in the first instance.
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.
You can ask us or third parties to stop sending you marketing messages by contactin ug at any time. If you no longer wish to receive our email communications, you can unsubscribe at any time by clicking on the unsubscribe link at the end of each newsletter.
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CHANGES TO OUR PRIVACY POLICY
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Applicable law and Simple box’s practices change over time. If we decide to update our privacy policy, we will post the changes on our website. If we materially change the way in which we process your personal data, we will provide you with prior notice, or where legally required, request your consent prior to implementing such changes. We strongly encourage you to read our privacy policy and keep yourself informed of our practices. This privacy policy was last modified in July 2020.
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