True Momentum is committed to protecting our customers’ privacy and takes its responsibility regarding the security of customer information very seriously. We will be clear and transparent about the information we are collecting and what we will do with that information.
This policy sets out the following:
- What personal data we collect and process about you in connection with your relationship with us as a customer and through your use of our website, mobile applications, and online services;
- Where we obtain the data from;
- What we do with that data;
- How we store the data;
- Who we transfer/disclose that data to;
- How we deal with your data protection rights;
- And how we comply with the data protection rules.
- All personal data is collected and processed in accordance with data protection laws.
“True Momentum” (referred to as “we”, “us”, “our” or “True Momentum” in this policy) in this policy primarily refers to True Momentum, the main operating company. True Momentum is the “data controller” of all personal information that is collected and used about True Momentum customers.
Personal data means any information relating to you which allows us to identify you, such as your name, contact details, order reference number, payment details, and information about your access to our website.
We may collect personal data from you when you order our products (either directly or indirectly through our trusted third-party partners), create an account, use our website, or when you contact us.
Specifically, we may collect the following categories of information:
- Name, billing address, delivery address, e-mail address, telephone number, credit/debit card or other payment details;
- Order history, including information related to your frequently ordered meals;
- Information about your use of our website;
- The communications you exchange with us or direct to us via letters, emails, calls, and social media.
We will never ask for or collect personal details about your physical or mental health.
What Do We Use Your Personal Data for, Why, and for How Long?
Your data may be used for the following purposes:
- Providing products and services you request: we use the information you give us to perform the services you have asked for in relation to your orders;
- Credit or other payment card verification/screening: we use your payment information for accounting, billing, and audit purposes and to detect and/or prevent any fraudulent activities;
- Customer services communications: we use your data to manage our relationship with you as our customer and to improve our services and enhance your experience with us;
- Provide tailored services: we use your data to provide the information we believe is of interest to you, prior to, during, and after your order with us and to personalise the services we offer to you, such as special offers;
- Marketing: from time to time we may contact you with information regarding promotions on our products via e-communications. You will have the choice to opt-in or opt-out of receiving such communications by indicating your choice at the booking stage. You will also be given the opportunity on every e-communication that we send you to indicate that you no longer wish to receive our direct marketing material.
We will only process your personal data where we have a legal basis to do so. The legal basis will depend on the reasons we have collected and need to use your personal data for.
In most cases, we will need to process your personal data so we can enter into our contract of sale with you.
We will not retain your data for longer than is necessary by law to fulfil the purpose it is being processed for. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal data, the purposes for which we process it, and whether we can achieve those purposes through other means.
When we no longer need your personal data, we will securely delete or destroy it. We will also consider if and how we can minimise over time the personal data that we use, and if we can anonymise your personal data so that it can no longer be associated with you or identify you, in which case we may use that information without further notice to you.
Security of Your Personal Data
We follow strict security procedures in the storage and disclosure of your personal data, and to protect it against accidental loss, destruction, or damage. The data you provide to us is protected, by amongst other things, SSL (Secure Socket Layer) technology. SSL is the industry-standard method of encrypting personal information and credit card details so that they can be securely transferred over the Internet.
All payment details are transmitted over SSL across dedicated network infrastructure (Multiprotocol Label Switching-MPLS) and stored in compliance with Payment Card Industry Data Security Standards (PCI DSS).
Sharing Your Personal Data
- Credit and debit card companies that facilitate your payments to us, and anti-fraud screening, which may need information about your method of payment and to process payment or ensure the security of your payment transaction;
- Legal and other professional advisers, law courts, and law enforcement bodies in all countries we operate in, in order to enforce our legal rights in relation to our contract with you;
Your Personal Account
If our use of your personal data is based on your consent, you have the option to withdraw your consent to our processing and delete your personal data at any time by contacting us at any time.
We keep your personal information contained account for as long as you hold the account and as required by law. You may delete your account by contacting us and requesting the account and all information associated be deleted. Please note that general retention periods apply to any personal data we collected to enter into a contract with you or to perform that contract or because we have a legal obligation to process it.
Cookies and Site Tracking
Cookies are small text files that are transferred to your computer’s hard drive through your web browser to enable us to recognise your browser and help us to track visitors to our site; thus enabling us to understand better the products and services that will be most suitable to you. A cookie contains your contact information and information to allow us to identify your computer when you navigate our site for the purpose of helping you accomplish your order. Most browsers automatically accept cookies, but, if you wish, you can change these browser settings by accepting, rejecting, and deleting cookies. The “help” portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you choose to change these settings, you may find that certain functions and features will not work as intended. The cookies we use do not detect any information stored on your computers.
For more information about cookies and how to stop cookies from being installed visit the following website: http://www.allaboutcookies.org.
We use Google Analytics to monitor customer traffic patterns and site usage to help us develop the design and layout of the websites. This software does not enable us to capture any personal information.
Your Right to Complain
You have the right to make a complaint at any time to a supervisory authority, in this case, the Information Commissioners Office. The address to send in such a complaint is: https://ico.org.uk/concerns.
Your Data Protection Rights
Under certain circumstances, by law, you have the right to:
- Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding/using it;
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it;
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below);
- Object to processing of your personal information 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 ground. You also have the right to object to our processing your personal information for direct marketing purposes;
- Object to automated decision-making including profiling, that is not to be subject of any automated decision-making by us using your personal information or profiling of you;
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it;
- Request transfer of your personal information in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format;
- Withdraw consent: in the limited circumstances where you may have provided your consent to the collection, processing, and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
If you want to exercise any of these rights, then please call us on 0191 291 4045 and speak to one of the team who will be happy to take you through the process, or email us at email@example.com and we will be happy to help.
You will not have to pay a fee to access your personal information (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 circumstances.
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.
Date of Issue: May 2022