Privacy Policy

1. Information that we collect

We may collect data in the following ways:

• When you visit one of our stores
• When you use our website
• When  you use our mobile app
• When you sign up for an Oodles account using any of the above online services
• When you interact with us, whether that is in person, online or via social media

We may collect information using the following methods:

• Information that you share with us
• Information that we collect through our services
• Information that we collect through our partners
• Information that we collect through other sources

Please note, that you are not obliged to share any personal information with us should you wish not to. In certain circumstances, we may not be able to provide you with the service proposed should you refuse to adhere to the terms of the interaction requested.

Our site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by external/third-party websites and we advise you to check the privacy policies of any such websites before providing any data to them.

2. What Data Do We Collect?

We may request you to provide the following information to us, this may depend on how you interact with us:

• Personal details such as; your name, address, email address, phone number, birthday information, and contact information, when you register with our online services i.e. our website or mobile app, enter a competition, contact us via phone or through our social media;
• Profile/demographic information such as; age, gender, job title, profession;
• Account information to access our online services/make a purchase with us
• Other personal information you choose to provide us when you interact with us (including but not limited to our Oodles brand social media platforms).

3. Other ways we may collect your information

We may use other technologies to collect information from you, your computer system or your mobile device when you visit one of our stores, use our online service or technologies. Such technologies may include but are not limited to; cookies, local shared objects and web beacons.

We may also collect information about your;

• IP address
• Smart device, mobile or computer operating system
• Browser type
• Various mobile device settings
• Online activity on other websites, apps or social media

4. How We Use Your Data

All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under GDPR at all times.

Our use of your personal data will always have a lawful basis, either because it is necessary for our services of a contract with you, or because you have consented to our use of your personal data (e.g. by subscribing to emails, requesting a delivery), or because it is in our legitimate interests. Specifically, we may use your data for the following purposes:

• Providing and managing your access to our site;
• Personalising and tailoring your experience on our site;
• Supplying our products to you (please note that we require your personal data in order to enter into a contract with you);
• Personalising and tailoring our products and services for you;Replying to emails, website messages or phone calls from you;
• Supplying you with emails that you have opted into (you may unsubscribe or opt out at any time by clicking unsubscribe at the bottom of our emails or by contacting us via the contact form on site;
• Market research;
• Analysing your use of our site and gathering feedback to enable us to continually improve our site and your user experience;

With your permission and/or where permitted by law, we may also use your data for marketing purposes which may include contacting you by email, telephone, post or SMS with information, news and offers on our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

You have the right to withdraw your consent to us using your personal data at any time and to request that we delete it.

We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.

5. How and Where Do We Store Your Data?

We only keep your personal data for as long as we need to in order to use it as described above in section 6, and/or for as long as we have your permission to keep it.

Your data will only be stored in the UK.

Data security is very important to us, and to protect your data we have taken suitable measures to safeguard and secure data collected through our site.

Steps we take to secure and protect your data include:

• Secure Server
• Secure and password-protected files
• Limited users and admins on data-sensitive files
• Limited physical access to servers and computers.

6. Do We Share Your Data?

Subject to section 8.2, and the Oodles Franchise network, we will not share any of your data with any third parties for any purposes.

In certain circumstances, we may be legally required to share certain data held by us, which may include your personal data, for example, where we are involved in legal proceedings, where we are complying with legal obligations, a court order, or a governmental authority.

7. How Can You Control Your Data?

When you submit personal data via our site, you may be given options to restrict our use of your data. In particular, We aim to:

• Give you strong 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 and at the point of providing your details, or by logging into your Account and managing your preferences.
• You may also wish to sign up for one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you from receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

8. How Can You Access Your Data?

You haYou have the right to ask for a copy of any of your personal data held by us (where such data is held). Under the GDPR, no fee is payable and we will provide any and all information in response to your request free of charge. Please contact us for more details at [email protected], or using the contact details below in section 14.

9. Privacy Policy for Minors

We understand how important it is to protect your privacy when you use our online services. We are especially committed to protecting the privacy of children, under the age of 18, who visit or use our online services. For more information on how a specific country protects children’s privacy, please see the country-specific addendum.

We urge parents to regularly monitor and supervise their children’s online activities. If you have any questions about our children’s privacy practices, please contact us at our Global or Local Data Protection Office using the contact information provided below. If you are contacting a Local Data Protection Office, please choose the office in the country in which you are a customer.

10. Your Rights

As a data subject, you have the following rights under GDPR, which this Policy and our use of personal data have been designed to uphold:

• The right to be informed about our collection and use of personal data;
• The right of access to the personal data we hold about you (see section 12);
• The right to rectification if any personal data we hold about you is inaccurate or incomplete (please contact us using the details in section 14);
• The right to be forgotten – i.e. the right to ask us to delete any personal data we hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like us to delete it sooner, please contact us by emailing [email protected];
• The right to restrict (i.e. prevent) the processing of your personal data;
• The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
• The right to object to us using your personal data for particular purposes; and
• Rights with respect to automated decision-making and profiling.

If you have any cause for complaint about our use of your personal data, please contact us using the details provided in section 14. If we are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.

For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.

11. Your Right to Withhold Information

You may access our site without providing any data at all. However, to use all features and functions available on our site you may be required to submit or allow for the collection of certain data.

12. Our Use of Cookies

Our site may place and access certain first-party cookies on your computer or device. First-party cookies are those placed directly by us and are used only by us. We use cookies to facilitate and improve your experience of our site and to provide and improve our products and services. We have carefully chosen these cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

All cookies used by and on our site are used in accordance with the current Cookie Law.

Before cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those cookies. By giving your consent to the placing of cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of cookies; however certain features of our site may not function fully or as intended.

Certain features of our site depend on cookies to function. Cookie Law deems these cookies to be “strictly necessary”. These cookies are shown below in section 13.5. Your consent will not be sought to place these cookies, but it is still important that you are aware of them. You may still block these cookies by changing your internet browser’s settings as detailed below in section 13.9, but please be aware that our site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

Our site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how our site is used. This, in turn, enables us to improve our site and the products and services offered through it. You do not have to allow us to use these cookies, however, whilst our use of them does not pose any risk to your privacy or your safe use of our site, it does enable us to continually improve our site, making it a better and more useful experience for you.

• The analytics service(s) used by our site use(s) cookies to gather the required information.
• In addition to the controls that we provide, you can choose to enable or disable cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
• You can choose to delete cookies on your computer or device at any time, however you may lose any information that enables you to access our site more quickly and efficiently including, but not limited to, login and personalisation settings.
• It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

13. Contacting Us

If you have any questions about our site or this Privacy Policy, please contact us by email at [email protected], by telephone on 0300 303 4145, or by filling out a head office contact form. Please ensure that your query is clear, particularly if it is a request for information about the data we hold about you (as under section 12, above).

14. Changes to Our Privacy Policy

WWe may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on our site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our site following the alterations. We recommend that you check this page regularly to keep up-to-date.

15. Definitions and Interpretation

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

“Account”	This means a sign-up to an account is required to access and/or use certain areas and features of Our Site;
“Cookie”	This means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;
“Cookie Law”	This means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;]
“Personal data”	This means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the [Data Protection Act 1998] OR [EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”)]
“We/Us/Our”	This means Oodles Chinese Holdings LTD, a limited company registered in England under company number is 10541595 whose registered address is 144 Charles Street, Leicester, LE1 1LB.