Privacy Policy

About this Policy
Why we collect your data
Information we collect / share
Using your personal data
Professional Contacts
Our legal basis for processing personal data
Disclosure of your personal data
Security of your personal data
Use of data processors
Retention of your data
Your Rights
Complaints
Contact us

1. About this Policy

Crumb The Revolution Ltd is committed to ensuring that your privacy is protected. We therefore take care to safeguard it. This notice outlines what data we collect, how we may use it, how we protect your data and your rights, and how you can exercise those rights.

We regularly check this notice to ensure we provide you with the most up-to-date information regarding our data processing activities. We strongly advise you to read this page from time to time to ensure you are happy with any changes that might be made.

This privacy policy has been prepared to be as comprehensive as possible, but it does not include an exhaustive list of every aspect of our collection and use of personal information. However, we would be happy to provide any further information or explanation about our practices. If you have any questions about this policy, please contact us using the details in the ‘Contact us’ section below.
This privacy policy was last updated in September 2022.

2. Why we collect your data

When collecting, processing, sharing and retaining the specified data, Crumb
The Revolution Ltd is the Data Controller.
We collect personal data for many reasons, including to; provide you with
services, communicate with you and send you information you have
requested. Depending on how you interact with us, we may process data for
the following reasons in order to:

process personal details required for the administration of your website ordering enquiry
record and contact you regarding payments you make to Crumb The Revolution Ltd
communicate with you regarding Crumb The Revolution Ltd fundraising or marketing activities
keep a record of your relationship with us for our own internal administrative purposes
conduct surveys, research and gather feedback
obtain information to improve Crumb The Revolution Ltd services and user experiences
comply with applicable laws and regulations, and requests from statutory agencies

3. Information we collect / share

We collect the following categories of personal information:

your full name
contact details – including your postal address, telephone number(s), and email address
date of birth
your bank details
records of your correspondence and engagement with us
other information you share with us This information may be collected via:
communications via email
any paper forms you complete
telephone conversations
digital forms completed via our website or online surveys
communication via social media Data may be shared with associated businesses and their employees as dictated by our internal policy.

4. Using your personal data

If you complete one of our website Contact Forms, enquiry about any of ours services or buy items from our website then we will need to gather your data.
We will keep all your information – including notes, letters and information given to us about you – in a confidential record that is specific to you.
We use a customer relationship management system (CRM) to record your personal data. This means that we can keep the information you provide us, so we are able to see the history and relevant details of your interaction with us. This ensures that we provide appropriate and accurate advice or support.

We take information security very seriously. No one is allowed access to our system or files unless they need this to provide the service to you, or one of the other purposes discussed in this notice.
When you call our office for advice or support, your call will only be recorded if you choose to leave a voicemail. This is to enable us to call you back to help resolve any queries that you may have. Recordings are deleted within 2 weeks.
We may use your data for financial / statistical reports to analyse ordering information in order to understand consumer behaviour and improve our services to you. These reports may include your personal information that you have given to us.

Fundraising/direct marketing

We would like to keep you up-to-date with our fundraising and marketing activities.
We use a range of marketing activities and channels to contact our customers – including our website, direct mail, email, telephone and social media.
We will send you marketing by email or post, on the basis of it being within our legitimate interests to do so, unless you opt out. See section 7 (‘Our legal basis for processing data’) for more information about our use of legitimate interests.

We send the following marketing materials:

updates about Crumb The Revolution Ltd – including newsletters and other publications informing you about our services and offers
fundraising activities – including how to take part in a fundraising event, requests for donations and updates on the impact that fundraising activities have had

We will never share or sell your personal data to a third-party organisation for its marketing, fundraising or campaigning purposes.
You can withdraw your consent, unsubscribe from or update your marketing preferences at any point by emailing us at info@crumbtherevolution.co.uk.
If you make any changes to your consent, we will update your record as soon as we possibly can. It may take up to 30 days for our systems to update and stop any postal communications from being sent to you. Email communications will, however, be stopped immediately.
Administrative communications to members In addition to the fundraising and marketing communications that you receive from Crumb The Revolution Ltd, we will also communicate with you by post,

telephone, and email in relation to administrative and transactional matters.
For example, we may call you if we require additional information regarding a booking or if there is a problem with a payment.
As mentioned above, we may still need to communicate with you for administrative purposes even where you have opted out of marketing or fundraising communications from us.

5. Professional contacts

We may collect data about professional contacts and partners with whom we work, or to whom we provide professional services. Personal data collected in this way will be processed in accordance with data protection legislation and this policy.
We may send our professional partners information and updates about our work (primarily by email). Such contacts can opt out of receiving this information at any time.

6. Our legal basis for processing personal data

The Information Commissioners Office sets out 6 lawful bases for processing data, which are as follows:

An individual has given clear consent for you to process their data for a purpose;
The consent is necessary for a performance of a contract, or steps which you have been asked to take prior to entering into a contract;
The processing is necessary for you to comply with the law;
The processing is necessary to protect someone’s vital interests i.e. their life;
The processing is necessary for you to perform a task in the public interest or for your official functions and the task or function has a clear basis in law;
The processing is necessary for your legitimate interests or the legitimate interests of a third party.

Three of these lawful bases are relevant to the types of processing that we carry out. This includes information that is processed on the bases of:

a person’s consent – for example:
1. to send you an email with the relevant forms to complete your order or purchase
a contract – for example:
1. to provide you with booking terms and conditions
2. to provide our clients data in respect of payment and services
3. to use your data to proceed with processing an order, enquiry or purchase; to share your bank account data with the relevant payment processor
legitimate interests – for example:
1. sharing your personal details with our third-party baking company and / or third-parties authorised by us to ensure that customers receive the level of service they require
2. As a merchant services user, personal information including bank details may be collected via payment machines or terminals. This data may be shared with our third-party baking
  company to ensure that customers receive their required order and goods
3. to analyse restaurant use information in order to understand consumer behaviour and improve our services to you
4. sharing with police and security organisations in order to prevent or detect crime

Personal data may be legally collected and used if it is necessary for a legitimate interest of the organisation using the data, if its use is fair and does not adversely impact the rights of the individual concerned.
When we use your personal information, we will always consider if it is fair and balanced to do so and if it is within your reasonable expectations. We will balance your rights and our legitimate interests to ensure that we use your personal information in ways that are not unduly intrusive or unfair.

If you would like more information on our uses of legitimate interests, or to change our use of your personal data, please get in touch with us using the details in the ‘Contact us’ section below.

1. Disclosure of your personal data

We will not share any of your personal data to any third party – except where:

the transfer is to a secure data processor, which carries out data processing operations on our behalf (please see section 10 for more information)
we are required to do so by law, for example to law enforcement or regulatory bodies where this is required or allowed under the relevant legislation
we have obtained your consent to do so We will never share or sell your personal data to a third-party organisation for marketing, fundraising, or campaigning purposes.
Security of your personal data We use appropriate technical and organisational measures and precautions to protect your personal data and to prevent the loss, misuse or alteration of
your personal data.

We will never share or sell your personal data to a third-party organisation for marketing, fundraising, or campaigning purposes.

2. Security of your personal data

We use appropriate technical and organisational measures and precautions to protect your personal data and to prevent the loss, misuse or alteration of your personal data.

Unfortunately, the transmission of information via the internet and electronically is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website and mailbox.

You should be aware of the following:

When we transfer and receive personal data, we redirect visitors to a web connection that uses SSL encryption (similar to that used for internet banking). We notify visitors of this connection through the use of a padlock symbol, which will appear in your address or status bar.
Some of our forms allow our visitors to ask questions about our products or services. You should be aware that these messages are not sent over an encrypted connection and the possibility exists, however minimal, that an unauthorised individual may be able to intercept this information.
We, therefore, recommend that you do not use unsecure forms and emails to send personal data, such as financial information. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
We encourage you to review the privacy statements of websites you choose to link to or from the Crumb The Revolution Ltd website so that you understand how these sites collect, use and share your information. We are not responsible for the privacy statements, security or other contents on sites outside of our own website.

3. Use of data processors

We may use a third-party supplier to conduct surveys on our behalf. You can find out more about the suppliers that we use by getting in touch with us using the details in the ‘Contact us’ section below.
We actively screen and monitor these companies to maximise the protection of your privacy and security. They are only permitted to use the data in accordance with relevant data protection legislation, under strict instructions from us, and in accordance with a data processing agreement entered into between Crumb The Revolution Ltd and the supplier.

4. Retention of your data

When making a booking or purchase, your data will be retained until after your booking or purchase has been completed.
Your data will be retained for a period of up to 6 years from the booking date or until all outstanding monies have been paid, whichever is the greater.
Once the retention period has expired, the information will be confidentially disposed or permanently deleted.

5. Your rights

You have many rights under Data Protection legislation. These include:

Right of Access
You have the right to know what personal data and supplementary information we hold about you. Requests for this data / information need to be in writing. Reasonable adjustments will be made under the Equality Act 2010 for disabled persons.
Data / information will be supplied as soon as possible, however, this may take up to one calendar month from receipt of the request or longer if your request is complex. We will not charge you for this other than in exceptional circumstances. You will be asked for proof of identity as we need to ensure we are only releasing your personal data to you.
1. This is called a data subject access, and can be done by: emailing info@crumbtherevolution.co.uk
2. writing to the Data Protection Manager, c/o Crumb The Revolution Ltd, 1 Little Shambles, York, YO1 7LY
Right to be informed
You have the right to be informed how your personal data will be collected and used. You will be directed to a copy of our Privacy Policy at the time we collect any personal data, this includes the lawful bases and purposes for processing your personal data, retention periods and who it may be shared with.
Right to withdraw consent
Where we process your data based on your consent (for example, to send you fundraising or marketing texts or emails), you can withdraw that consent at any time. To do this, or to discuss this right further with us, please contact us using the details in the ‘Contact us’ section below.
Right to object
You also have a right to object to us processing data where we are relying on it being within our legitimate interests to do so (for example, to send you direct marketing by email or post). To do this, or to discuss this right further with us, please contact us using the details in the ‘Contact us’ section below.
Right to restrict processing
In certain situations, you have the right to ask for processing of your personal data to be restricted because there is some disagreement about its accuracy or legitimate usage. You can make a request for restriction verbally or in writing. We have one calendar month to respond to a request.
Right of erasure
In some cases, you have ‘the right to be forgotten’ (i.e. to have your personal data deleted from our system). An individual can make a request for erasure verbally or in writing. We have one calendar month to respond to a request. Please note that this right is not absolute and only applies in certain circumstances.
Right of rectification
You have the right, if you believe our records are incomplete to be updated. In certain circumstances you have the right to have inaccurate personal data rectified. You can make a request for
rectification verbally or in writing. We have one calendar month to respond to a request for rectification.
Right to data portability
You have the right to obtain and reuse your personal data for your own purposes across different service providers. This information will be provided to you in a structured, commonly used and machine-readable form and will be provided free of charge.
If technically feasible, you have the right to request that the data is transferred from us to another organisation. We are, however, not required to adopt or maintain processing systems that are technically compatible with other organisations. If the personal data concerns more than one individual, we will need to consider whether providing the information would prejudice the rights of the other individual.
Requests must be provided in writing and whilst we will aim to respond immediately and within one calendar month, this can be extended by two months where a request is complex, or we have received a number of requests. We will, however, inform you within one calendar month of receipt of the request and explain why an extension is necessary.

6. Complaints

If you have any complaints about the way in which we have used your data, please get in touch with us using the details in the ‘Contact us’ section below.
We would be happy to help and discuss your concerns.
In addition, you are also entitled to make a complaint to the Information Commissioner’s Office.

7. Contact Us

If you have any questions about this policy, would like more information, or want to exercise any of the rights set out in section 10 above, you can get in touch with us in the following ways:

info@crumbtherevolution.co.uk
Crumb The Revolution Ltd, 1 Little Shambles, York, YO1 7LY