Privacy Policy

Effective as of 8 June 2021

Introduction
1. Thank you for visiting the Website and/or using the Services. In order to operate the Website and provide the Services, and to improve the Website’s offering, we collect information from you. Even if you are just browsing the Website, we may receive certain information from you, for example the device you access the Website from and your IP address.
2. Please read this Privacy Policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us in the event you have a complaint. Please rest assured that we take your privacy very seriously.
3. In compliance with the GDPR, this Privacy Policy sets out our obligations in respect of the collection, retention, safeguarding of and access to your Personal Data. For the purposes of GDPR, we are a Data Controller.
4. Please read this Privacy Policy in full, as by continuing to use the Website you are deemed to be bound by its contents. Please also read the Website Terms & Conditions (www.sweetnexus.co.uk/termsandconditions) and any other terms applicable to your participation in the Services (together the “Key Terms”). IF YOU DO NOT AGREE TO ANY OF THE KEY TERMS, PLEASE STOP USING THE WEBSITE IMMEDIATELY.

Definitions and interpretation

In this Privacy Policy, the following definitions are used:

Data	collectively all information that you submit to Sweet Nexus Limited via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;
Cookies	a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the Cookies used by this Website are set out later in this Privacy Policy;
Data Protection Laws	any applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK;
GDPR	the General Data Protection Regulation (EU) 2016/679;
Personal Data	any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier. This includes, but is not limited to, name, email address, postal address, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person;
Services	Campaign Management Tool operated by Sweet Nexus Limited or any other company operated within the Sweet Nexus Group, plus any other services offered by Sweet Nexus Limited or Sweet Group Company from time to time.
Sweet Nexus Limited, we, our or us	Sweet Nexus Limited, a company incorporated in England and Wales with registered number 13382100 whose registered office is at 12 Dunworth Mews, London, W11 1LE;
UK and EU Cookie Law	the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;
User or you	any third party that accesses the Website and is not either (i) employed by Sweet Nexus Limited and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Sweet Nexus Limited and accessing the Website in connection with the provision of such services; and
Website	the website that you are currently using, www.sweetnexus.co.uk, and any sub- domains of this site unless expressly excluded by their own terms and conditions.

In this Privacy Policy, unless the context requires a different interpretation:

the singular includes the plural and vice versa;
references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this Privacy Policy;
a reference to a person includes firms, companies, government entities, trusts and partnerships;”
“including" (or “includes”) is understood to mean "including without limitation" (“includes without limitation”);
reference to any statutory provision includes any modification or amendment of it;
the headings and sub-headings do not form part of this Privacy Policy.

Scope of this Privacy Policy
1. This Privacy Policy applies only to the actions of Sweet Nexus Limited and Users with respect to this Website and the Services. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites and merchant websites.
Data collected
1. We may collect the following Data, which includes Personal Data, from you:
  1. Your name, age, date of birth and profession;
  2. Your contact details, including: postal address, telephone numbers and e-mail address;
  3. Your credit card or other payment information;
  4. Details of services provided and/or orders made by you;
  5. Details of events attended by you (if applicable);
  6. Your competition or other contest entries;
  7. Your communication and marketing preferences;
  8. Your interests, preferences, feedback and survey responses;
  9. Your correspondence and communications with us;
  10. Other publicly available Personal Data, including any which you have shared via a public platform (such as a Twitter feed, public Facebook page or a company website);
  11. Information about your visit to the Website, including the full Uniform Resource Locators (URL), clickstream to, through and from the Website (including date and time), pages you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page;
  12. Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, browser plug-in types and versions, and operating system and platform.
  13. Information collected from the Website and elsewhere across the internet through cookies, web beacons, pixel tags, device identifiers and other technologies including information about your shopping habits and preferences,
    in each case, in accordance with this Privacy Policy.
How we collect Data
1. We collect Data in the following ways:
  1. When you opt-in to receive marketing or other communications from us;
  2. When you sign-up to, and subsequently use, the Services;
  3. When you enter our competitions or other contests;
  4. When you correspond with us (by phone, email or otherwise);
  5. When you make payments to us, through this Website or otherwise;
  6. Information that we may collect automatically when you use the Website, for example with regard to each of your visits to the Website it may, independently or through third-party data analytics tools or services such as Google Analytics, automatically collect information as you use the Services and/or the Website;
  7. Information gathered through cookies and other similar technology to distinguish you from other users of the Website, to assist us in providing you with a good experience when you browse the Website and also allows us to improve the Website;
  8. Via third parties, for example affiliate networks.
Data that is collected automatically
1. For the duration of your access to the Website, we may collect certain Data automatically, for example certain information about your visit to the Website, including your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content. This information helps us to make improvements to Website content and navigation. Any Data collected automatically will be in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed "Cookies".
Our use of Data
1. Data may be used by us for the following reasons, including:
  1. internal record keeping;
  2. improvement of our product and the Services;
  3. transmission by email of marketing materials that may be of interest to you; and
  4. contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Website,
    in each case, in accordance with this Privacy Policy.
The grounds on which we may store and use your Personal Data.
We might store and use your Personal Data on the following legal grounds:
1. Consent:
  - for example, if you have opted in to receive marketing communications and/or news from us
2. Fulfilment of a Contractual Obligation/Performance of Services:
  - for example, if you have participated in the Services via the Website, we will store and process your Personal Data insofar as it is necessary to provide such Services.
3. Legitimate Interest:
  - for example, (i) to provide you with technical support if requested; and (ii) if you have previously provided us with your contact details in the course of business (for example, you have signed up to receive Services via the Website), we may send you electronic communications relating to similar goods/services that we may provide from time to time. You will always be given the opportunity to opt-out of the latter form of communication via an ‘unsubscribe’ link. If relying on legitimate interest as a lawful ground for processing your Personal Data, we will always take into account your rights and interests prior to sending any such communications.
4. Legal and Compliance Purpose(s):
  - for example, to assist us in keeping the Website safe and secure; to use profiling tools to identify behavior which breaches the terms upon which you are using the Website and/or Services; and to protect our rights or property.
Who we may share Data with
1. We may share your Data with the following groups of people for the following reasons:
  1. any of our group companies, customers or affiliates - to ensure the proper administration of your requests and preferences during signing up to one of our campaigns or promotional activities;
  2. our employees, agents and/or professional advisors - to provide additional services or offers in accordance with your preference to receive such information;
  3. third party service providers who provide services to us which require the processing of Personal Data - such as our affiliate partners;
  4. third party payment providers who process payments made through our Website or affiliate partners websites;
  5. relevant authorities - for the purposes of detection of crime such as money laundering or the collection of taxes or duties;
  6. Users of Sweet Nexus products who elected to be contacted by other members for the purposes of responding to their posts and offers, subject to acceptance of Sweet Nexus applicable terms,
  in each case, in accordance with this Privacy Policy.
Keeping Data secure
1. We will use technical and organisational measures to safeguard your Data, for example:
  1. access to your account is controlled by a password and a user name that is unique to you;
  2. we store Data on secure servers;
  3. payment details are encrypted using SSL technology (typically you will see a lock icon or green address bar (or both)) in your browser when we use this technology;
  4. Access to Personal Data within our organisation shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
2. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: info@sweetnexus.co.uk.
Data retention
1. We will not retain your Personal Data for longer than necessary for the purposes set out in this Privacy Policy. Different retention periods apply for different types of Data.
2. Should you request a deletion of any Personal Data that we hold on you, we will take all commercially reasonable steps to remove your Personal Data from our database, provided that nothing in this Privacy Policy shall prevent us from retaining information strictly necessary for and in compliance with our business practices (for example, for the purposes of dispute resolution, enforcement and to comply with legal agreements).
Your rights
1. You have the following rights in relation to your Data:
  1. Right to access - the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
  2. Right to correct - the right to have your Data rectified if it is inaccurate or incomplete.
  3. Right to erase - the right to request that we delete or remove your Data from our systems.
  4. Right to restrict our use of your Data - the right to "block" us from using your Data or limit the way in which we can use it.
  5. Right to data portability - the right to request that we move, copy or transfer your Data.
  6. Right to object - the right to object to our use of your Data including where we use it for our legitimate interests.
2. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: info@sweetnexus.co.uk.
3. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner's Office (ICO). The ICO's contact details can be found on their website at https://ico.org.uk.
4. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.
Links to other websites
1. This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This Privacy Policy does not extend to your use of such websites. You are advised to read the Privacy Policy or statement of other websites prior to using them.
Changes of business ownership and control
1. Sweet Nexus Limited may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Sweet Nexus Limited. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the Data for the purposes for which it was originally supplied to us. We may also disclose Data to a prospective purchaser of our business or any part of it as part of any confidential due diligence exercise.

Cookies

This Website may place and access certain Cookies on your computer. Sweet Nexus Limited uses Cookies to improve your experience of using the Website and to improve our range of products and the Services. Sweet Nexus Limited has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.
All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.
Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Sweet Nexus Limited to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.

This Website may place the following Cookies:

Type of Cookie	Purpose
Strictly necessary Cookies	These are required for the operation of our Website. They include, for example, Cookies that enable you to log into secure areas of our Website, use a shopping cart or make use of e-billing services.
Analytical/performance Cookies	They allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality Cookies	These are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting Cookies	These record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.
You can choose to delete or remove your consent to certain Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
For more information generally on Cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete Cookies from your computer.

General
1. You may not transfer any of your rights under this Privacy Policy to any other person. We may transfer our rights under this Privacy Policy where we reasonably believe your rights will not be affected.
2. If any court or competent authority finds that any provision of this Privacy Policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Privacy Policy will not be affected.
3. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
4. This Privacy Policy will be governed by and interpreted according to the laws of England. All disputes arising under this Privacy Policy will be subject to the exclusive jurisdiction of the English courts.
Changes to this Privacy Policy
1. Sweet Nexus Limited reserves the right to change this Privacy Policy as we may deem necessary from time to time or as may be required by law. Any material changes will be promptly notified to you and you are deemed to have accepted the terms of the Privacy Policy on your first use of the Website following the alterations.
Contact Details
1. Our registered office and principal place of business is at 12 Dunworth Mews, London, W11 1LE. You can contact us by writing to the business address given above, or by emailing info@sweetnexus.co.uk.