BACKGROUND:

LSA Retail Telscombe Ltd 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, http://sunup.codelantic-staging.club/ (“SUNCUP Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

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

1.Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

“Account”	means an account required to access and/or use certain areas and features of Our AB Site;
“Cookie”	means a small text file placed on your computer or device by Our AB Site when you visit certain parts of Our AB Site and/or when you use certain features of Our AB Site. Details of the Cookies used by Our AB Site are set out in Clause 14, below;
“Cookie Law”	means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 and UK Cookie Laws; and
“We/Us/Our”	means LSA Retail Telscombe Ltd , a company registered in England under 10465246, whose registered address is 95 St Dunstan Hill, Cheam, Surrey SM1 2LW and whose main trading address of 11-15 Market Place, Bexleyheath DA6 7DZ for Alli Bhavan supermarket store.

2.Information About Us

Our AB Site (www.Allibhavan.com) is owned and operated by LSA Retail Telscombe Ltd , a limited company registered in England under company number 10465246, whose registered address is 95 St Dunstan Hill, Cheam, Surrey SM1 2LW and whose main trading address is 11-15 Market Place, Bexleyheath DA6 7DZ for Alli Bhavan supermarket store.

3.What Does This Policy Cover?

This Privacy Policy applies only to your use of Our AB Site. Our AB 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.

4.What Is Personal Data?

Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

5.What Are Your Rights?

Under the Data Protection Legislation, you have the following rights, which 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 Clause 15We will always work to uphold:

1. The right to access the personal data we hold about you. Clause 13 will tell you how to do this.
2. 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 Clause 15 to find out more.
3. 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 Clause 15 to find out more.
4. The right to restrict (i.e. prevent) the processing of your personal data.
5. The right to object to us using your personal data for a particular purpose or purposes.
6. 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.
7. 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.
8. Rights relating to automated decision-making and profiling.

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 Clause 15.

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 Clause 15.

6.What Data Do We Collect and How?

Depending upon your use of Our AB Site, we may collect and hold some or all of the personal and/or non-personal data set out below. Please also see Clause 14 for more information about Cookie Policy <<insert link>>]. We do not collect any sensitive personal data such as data relating to children and/or criminal convictions and/or offences.Identity Information such as full name, title, date of birth and gender

1. Contact Information such as postal address, email address and telephone numbers.
2. Business Information such as business name, job tittle and profession.
3. Payment Information such as card details, card holder’s details and bank account.
4. Profile Information such as preferences, interest, login details and purchase history.
5. Technical Information such as IP address, browser type 7 version, operating system and other relevant software details.
6. Other Data from 3^rd parties such as technical information, contact information and profile information.

7.How Do We Use Your Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following items describes how we may use your personal data.Registering you on Our AB Site

1. Providing and managing your account.
2. Providing and managing your access to Our AB Site.
3. Personalising and tailoring your experience on Our AB Site
4. Administering Our AB Site.
5. Administering Our business.
6. Supplying Our products and/or services to you.
7. Managing payments for Our products and/or services.
8. Personalising and tailoring Our products and/or services for you.
9. Communicating with you.
10. Supplying you with information by email, post and/or by other medium that you have opted-in-to (you may opt-out at any time).

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and/or telephone and/or text message and/or post with information, news, and offers on our products and/or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

Third Parties (whose content appears on OurAB Site may use third-party Cookies, as detailed below in Clause 14. Please refer to Part 14 for more information on controlling cookies for Ours and third parties’. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.

8.How Long Will We Keep Your Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept until you ask us to delete your personal information through our contact details as set out in Clause 15.

9.How and Where Do We Store or Transfer Your Personal Data?

We will store your personal data including non-personal data will be transferred to, processed, and stored in the UK. This means that it will be fully protected under the Data Protection Legislation.

We may transfer or process or store your personal data including non-personal data in country 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 including non-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.

We ensure that your personal data is protected under binding corporate rules. Binding corporate rules are a set of common rules which all our group companies are required to follow when processing personal data. For further information, please refer to the

 Information Commissioner’s Office.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

• 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 are legally required to do so;

10.Do We Share My Personal Data?

We will not sell, rent, lease or disclose your personal data with any third parties subject to the following exceptions. We share some of your personal data with the following parties for the following purposes:

• The Government authorities and law enforcement when necessary to comply with the legal obligations.

• Suppliers we work with, to render services adequately.
• Companies within the group holding and/or subsidiaries, including affiliates, to provide the best services to you.
• Payment card, bank and fraud management services provider to process payments and prevent fraud, or for debt recovery.

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(s) that we have used it, as specified in this Privacy Policy.

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.

If any personal data is transferred outside of the UK, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained  above in Clause 9.

11.How Can You Control Your Personal Data?

11.1 In addition to your rights under the  Data Protection Legislation, set out in  Clause 5 5, when you submit personal data via Our AB Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails or at the point of providing your details or by managing your account).

12.Can You Withhold Information?

You may access Our AB Site without providing any personal data at all. However, to use all features, functions and/or make orders available on Our AB Site you may be required to submit or allow for the collection of certain data.

You may restrict our use of Cookies. For more information, see Clause 14 for Our Cookie Policy here

13.How Can You Access Your 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. This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Clause 15. If there is a Subject Access Request Form is made available for you to use at Our AB Site then we strongly recommend you to use this form to communicate to us in writing as 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.

14.How Do You Use Cookies?

Our AB Site may place and access certain Cookies on your computer or device as set out in Our Cookie Policy, available from here.

15.How Do You Contact Us?

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: DPO@Allibhavan.com

Telephone number: 0208 303 3261

Postal Address: Suite 1, 14 Bourne Court, Southend Road, Woodford Green IG8 8HD.

16.Changes to this Privacy Policy

We may change this Privacy Policy 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 posted on Our AB Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our AB Site following the alterations. We recommend that you check this page regularly to keep up-to-date.