1. PURPOSE OF THIS NOTICE
This notice describes how we collect and use personal data about you, in accordance with the
General Data Protection Regulation (GDPR), the Data Protection Act [1998 until 25th May or the 2018
Act when implemented] and any other national implementing laws, regulations and secondary
legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’).
Please read the following carefully to understand our practices regarding your personal data and how
we will treat it.
2. ABOUT US
(“Habis Ltd”, “we”, “us”, “our” and “ours”) is a café, bar, and restaurant.
Habis Ltd is a company registered in England and Wales with company registration number
09803424 with its registered office is 23 Main Street, Littleport, Cambridgeshire, England, CB6 1PH
For the purpose of the Data Protection Legislation and this notice, we are the ‘data controller’. This
means that we are responsible for deciding how we hold and use personal data about you. We are
required under the Data Protection Legislation to notify you of the information contained in this privacy
We have appointed a Data Protection Lead. Our Data Protection Lead is our Data Protection Point of
Contact and is responsible for assisting with inquiries in relation to this privacy notice or our
treatment of your personal data. Should you wish to contact our Data Protection Point of Contact you
can do so using the contact details noted in paragraph 16 (Contact Us), below.
3. HOW WE MAY COLLECT YOUR PERSONAL DATA
We obtain personal data about you, for example, when:
- you request a quote from us in respect of the services we provide;
- you engage us via our booking system to provide our services;
- you contact us by email, telephone, post, our website or social media (for example when you
have a query about our services);
4. THE KIND OF INFORMATION WE HOLD ABOUT YOU
The information we hold about you may include the following:
your personal details (such as your name and/or address, telephone number);
details of contact we have had with you in relation to the provision, or the proposed provision, of
our services (e.g. in the case of booking a private function);
details of any services you have received from us;
our correspondence and communications with you;
information about any complaints and enquiries you make to us;
information from research, surveys, and marketing activities;
pseudonymised information about usage of our website and social media services such as
session tracking cookies
5. HOW WE USE PERSONAL DATA WE HOLD ABOUT
We may process your personal data for purposes necessary for the performance of our booking with
you to comply with our legal obligations.
We may process your personal data for the purposes of our own legitimate interests provided that
those interests do not override any of your own interests, rights and freedoms which require the
protection of personal data. This includes processing for marketing, business development, statistical
and management purposes.
We may process your personal data for certain additional purposes with your consent, and in these
limited circumstances where your consent is required for the processing of your personal data then
you have the right to withdraw your consent to processing for such specific purposes.
Please note that we may process your personal data for more than one lawful basis depending on the
specific purpose for which we are using your data.
Situations in which we will use your personal data
We may use your personal data in order to:
carry out our obligations arising from any agreements entered into (which will most usually be for
the provision of our services);
provide you with information related to our services and our events and activities that you request
from us or which we feel may interest you, provided you have consented to be contacted for such
seek your thoughts and opinions on the services we provide; and
notify you about any changes to our services.
In some circumstances we may anonymise or pseudonymise the personal data so that it can no
longer be associated with you, in which case we may use it without further notice to you.
If you refuse to provide us with certain information when requested, we may not be able to perform
the arrangement we have entered into with you. Alternatively, we may be unable to comply with our
legal or regulatory obligations.
We may also process your personal data without your knowledge or consent, in accordance with this
notice, where we are legally required or permitted to do so.
We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is
When assessing what retention period is appropriate for your personal data, we take into
the requirements of the services provided;
any statutory or legal obligations;
the purposes for which we originally collected the personal data;
the lawful grounds on which we based our processing;
the types of personal data we have collected;
the amount and categories of your personal data; and
whether the purpose of the processing could reasonably be fulfilled by other means.
Change of purpose
Where we need to use your personal data for another reason, other than for the purpose for which we
collected it, we will only use your personal data where that reason is compatible with the original
Should it be necessary to use your personal data for a new purpose, we will notify you and
communicate the legal basis which allows us to do so before starting any new processing.
6. DATA SHARING
Why might you share my personal data with third parties?
We will share your personal data with third parties where we are required by law, where it is
necessary to administer the relationship between us or where we have another legitimate interest in
Which third-party service providers process my personal data?
“Third parties” includes third-party service providers and the members of our any of our firm’s
professional networks. The following activities are carried out by third-party service providers
administration services and marketing services.
All of our third-party service providers are required to take commercially reasonable and appropriate
security measures to protect your personal data. We only permit our third-party service providers to
process your personal data for specified purposes and in accordance with our instructions.
What about other third parties?
We may share your personal data with other third parties, for example in the context of the possible
sale or restructuring of the business. We may also need to share your personal data with a regulator
or to otherwise comply with the law.
7. TRANSFERRING PERSONAL DATA OUTSIDE THE
EUROPEAN ECONOMIC AREA (EEA)
Personal information in the EEA (which means all the EU countries plus Norway, Iceland and
Liechtenstein) (“EEA”) is protected by data protection laws but other countries do not necessarily
protect your personal information in the same way.
We may use service providers based outside of the EEA to help us provide our services to you and
this means that we may transfer your information to service providers outside the EEA for the purpose
of providing our services to you. For example we utilise services such, and not limited to, WordPress,
Outlook and Cloud Accounting services such as QuickFile and parts of these services may for
example be hosted on servers located within the United States or managed and supported from
outside the EEA to for example to ensure service availability and security around the clock.
We take steps to ensure that where your information is transferred outside of the EEA by our service
providers and hosting providers, appropriate measures and controls in place to protect that
information in accordance with applicable data protection laws and regulations. This may be that there
is an adequacy decision by the European Commission in relation to these countries and therefore
they will be deemed to provide an adequate level of protection for your personal information. In each
case, such transfers are made in accordance with the requirements of Regulations (EU) 2016/679
(the General Data Protection Regulations or “GDPR”) and may be based on the use of the European
Commission’s Standard Model Clauses for transfers of personal data outside the EEA.
By using our website, products or services or by interacting with us in the ways described in this
Privacy Notice, you consent to the transfer of your information outside the EEA in the circumstances
set out in this Privacy Notice where necessary for the delivery of our services. If you do not want your
information to be transferred outside the EEA you may not be able to use all our services.
Should you require further information about these protective measures, or confirmation as to if the
services we deliver to you involve such transfers please contact us using the contact details outlined
in section 16 below.
8. DATA SECURITY
We have put in place commercially reasonable and 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 data security breach and will notify you
and any applicable regulator of a suspected breach where we are legally required to do so.
9. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Should your personal
information change, please notify us of any changes of which we need to be made aware by
contacting us, using the contact details below.
Your rights in connection with personal data
Under certain circumstances, by law you have the right to:
Request access to your personal data. This enables you to receive details of the personal data
we hold about you and to check that we are processing it lawfully.
Request correction of the personal data that we hold about you.
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 exercised your right to object to
processing (see below).
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 basis. You also have the right to object where we are processing
your personal information for direct marketing purposes.
Request the restriction of processing of your personal data. This enables you to ask us to
suspend the processing of personal data about you, for example if you want us to establish its
accuracy or the reason for processing it.
Request the transfer of your personal data to you or another data controller if the processing is
based on consent, carried out by automated means and this is technically feasible.
If you want to exercise any of the above rights, please email our data protection point of contact:
You may request details of personal information which we hold about you under the Data Protection
Act 1998. Until 25 th May 2018 a nominal charge of £10 may be made to cover administrative costs
involved in accordance with the Data Protection Act 1998.
After the 25 th May 2018 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 for access is clearly
unfounded or excessive. Alternatively, we may refuse to comply with the request in such
We may need to request specific information from you to help us confirm your identity and ensure
your right to access the information (or to exercise any of your other rights). This is another
appropriate security measure to ensure that personal information is not disclosed to any person who
has no right to receive it.
10.RIGHT TO WITHDRAW CONSENT
In the limited circumstances where you may have provided your consent to the collection, processing
and transfer of your personal data for a specific purpose (for example, in relation to direct marketing
that you have indicated you would like to receive from us), you have the right to withdraw your
consent for that specific processing at any time. To withdraw your consent, please email our data
protection point of contact:
Once we have received notification that you have withdrawn your consent, we will no longer process
your personal information (personal data) for the purpose or purposes you originally agreed to, unless
we have another legitimate basis for doing so in law.
11.CHANGES TO THIS NOTICE
We may make changes to this Privacy Notice from time to time. Any changes we may make to our
privacy notice in the future will be provided to you by being updated on our website
This privacy notice was last updated on 12 th June 2018.
We are committed to ensuring that your information is secure. In order to prevent unauthorised
access or disclosure we have put in place suitable physical, electronic and managerial procedures to
safeguard and secure the information we collect online.
Unfortunately, no data transmission over the Internet or any other network can be guaranteed as
100% secure. As a result, while we strive to protect your personal data, we cannot ensure and do not
warrant the security of any information you transmit to us, and this information is therefore transmitted
at your own risk.
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you
agree, the file is added, and the cookie helps analyse web traffic or lets you know when you visit a
particular site. Cookies allow web applications to respond to you as an individual. The web application
can tailor its operations to your needs, likes and dislikes by gathering and remembering information
about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about
webpage traffic and improve our website in order to tailor it to customer needs. We only use this
information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you
find useful and which you do not. A cookie in no way gives us access to your computer or any
information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but
you can usually modify your browser setting to decline cookies if you prefer. This may prevent you
from taking full advantage of the website.
We may collect information about your computer, including your IP address, operating system and
browser type, for system administration and in order to create reports. This is statistical data about
our users’ browsing actions and patterns and does not identify any individual directly.
We use Google Analytics to provide aggregated statistical data about our website visitors’ browsing
actions and patterns by providing usage data that helps us improve the website structure, design,
content and functions; this process does not purposely identify any individual user however it may be
technically possible to de-anonymise this analytical information based on the unique usage patterns
on the site.
Google Analytics is a web analytics tool that helps website owners understand how visitors engage
with their website. Google Analytics customers can view a variety of reports about how visitors
interact with their website so that they can improve it.
Like many services, Google Analytics uses first-party cookies to track visitor interactions as in our
case, where they are used to collect information about how visitors use our site. We then use the
information to compile reports and to help us improve our site.
Cookies contain information that is transferred to your computer’s hard drive. These cookies are used
to store information, such as the time that the current visit occurred, whether the visitor has been to
the site before and what site referred the visitor to the web page.
Google Analytics collects information anonymously. It reports website trends without identifying
You can opt out of Google Analytics without affecting how you visit our site. To opt out of being
tracked by Google Analytics across all website please visithttp://tools.google.com/dlpage/gaoptout.
If you have any questions regarding this notice or if you would like to speak to us about the manner in
which we process your personal data:
please emailData Protection Point of Contact at firstname.lastname@example.org
or telephone ourData Protection Point of Contacton07445831648
or write to us at
Habis Ltd, 23 Main Street, Littleport, Ely, Cambs, CB6 1PH
You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK
supervisory authority for data protection issues, at any time. The ICO’s contact details are as follows:
Information Commissioner’s Office