Website Information Terms, Conditions, Policies & Help

Introduction

Cromwells are committed to providing a professional product & service, and that involves protecting the privacy of our visitors and customers. This means that we'll protect the personal information of all visitors who access our websites or services through any mobile application, platform or device (collectively, the "Services"). We believe in total transparency and this privacy policy explains how Cromwells, ZPos Ltd (our Data Processor), our subsidiaries and affiliates collect, share, and use your personal information. You'll also find information about how you can exercise your privacy rights. By using our Services you agree to Cromwells using your personal information as described in this privacy policy. The terms "we", "us" or "our" are each intended as reference to Cromwells, accessible via cromwellsrestaurant.com, and any terms not defined in this privacy policy are defined in our Terms & Conditions.

Data handlers

The Data Controller for this website and its associated operations is Cromwells. The Data Processor is ZPos Ltd, located at Unit 15 Dorcan Business Village, Murdock Road, Swindon, Wiltshire, SN3 5HY. For the purposes of this policy these two entities shall hereby be referred to as the Controller and Processor, respectively.

Privacy Policy

We strive to make our website fully compliant with all privacy laws, including the GDPR. To help you digest our full policy, below is a table of contents.

1. Information we collect from you and why
2. Our use of collected information
3. Who we share personal information with
4. Legal basis for processing personal information
5. International data transfers
6. Security
7. Data retention
8. Your data protection rights
9. Links to third-party sites
10. Updates to this Privacy Policy
11. How to contact us

1. Information we collect from you

   The personal information that we may collect about you broadly falls into the following categories: 

   1. Information that you provide voluntarily 
      

      Certain parts of our Services may ask you to provide personal information voluntarily. 

      For instance:

      • Registration information:

        When you create a Cromwells member's account, sign-up or fill in forms on the Services, we collect information about you including your name, address, telephone number, email address and the password you create. Please note your password is stored in an encrypted format that cannot be hacked.

      • Transaction information:

        We collect information relating to your Orders, including payment information (e.g. part of your credit card number) using the secure services of our payment processors. Payment operations are outsourced to our payment processors and we do not store your full credit card information in our systems. We also collect delivery details (e.g. your physical address) to fulfil each delivery Order.

      • Information regarding your marketing preferences:

        We collect information about your preferences to receive marketing information any time you subscribe or unsubscribe.

      • Feedback:

        When you post messages and reviews of the Services or you contact us, for example with a question, problem or comment, we collect information about you including your name and the content of your query. If you contact our website operator's customer support teams, they will record and keep a record of your conversation for quality and training purposes and to aid in the resolution of your queries.

   2. Information that we collect automatically 
      

      When you access our Services, we may collect certain information automatically from your device.

      For instance:

      • Activity information:

        We collect information about your usage of the Services and information about you from the content you create and the notifications or messages you post or send as well as what you search for, look at and engage with.

      • Cookies and similar technologies:

        We use cookies and similar tracking technology to collect and use personal information about you (e.g. your Internet Protocol (IP) address, your device ID, your browser type and when, how often and how long you interact with the Services). For further information about the types of cookies and similar technologies we use, why, and how you can control such technologies, see our Cookies Policy.

   3. Information that we obtain from third party sources. 
      

      From time to time, we may receive personal information from third party sources, including advertising networks but only where we have checked that these third parties either have your consent to process the information or are otherwise legally permitted or required to share your personal information with us. This information may include your likely demographic group.

      For instance:

      • Analytics reports and market research surveys:

        We collect information from our third party affiliates about the way you respond to and engage with our marketing campaigns so that we can customise our marketing and Services accordingly.

      • We may also receive aggregated information in the form of audience segments from third party sources in order to display targeted advertising on digital properties operated by organisations like Facebook and Google.

2. Our use of collected information

   Examples of how we may use this information include: 

   1. Information that you provide voluntarily 

   • Registration information

     The registration information you provide when you create a Cromwells member's account allows us to give you access to the Services and to supply them to you under our Terms. We also use this information to authenticate your access to the Services, to contact you for your views and to notify you of important changes or updates to our Services.

   • Transaction information

     Your transaction information (such as the food items you add to your basket) allow us to process your Order and send you an accurate bill. It also helps us contact you where necessary. 

     Cromwells or our affiliates may contact you by email, phone or SMS to give you status updates or other information or to resolve problems with your account or Order. We may contact you by phone or SMS to provide you with status updates or other information regarding your Order. 

     Where you pay for your Order with a mobile payment or digital wallet service provider (such as Applepay or Pay with Google) we will send you transaction information via confirmation emails or SMS to the email address or phone number registered with that service provider (since this is required by those providers). 

     Sometimes we may use third party delivery companies; these companies may use your information to provide you with status updates on the delivery of your Order.

     We will also analyse information on completed transactions and successfully delivered Orders on the basis of data matching or statistical analysis so that we can administer, support, improve and develop our business and Services. Our analyses also help us detect and prevent fraud or other illegal activities or acts prohibited by our Terms or any policies applicable to the Services. 

   • Information regarding your marketing preferences

     Cromwells or our affiliates may market to you, where permitted by law, by post, email, telephone, mobile (i.e. SMS, in-app messaging and push notification) about our products or Services. 

     Where you have given your consent, we may share your information with third parties (e.g. other companies) in other sectors (such as food, drink and entertainment) so that they can tell you about goods or services which may interest you. 

     If you don't want us to use your data in this way or generally change your mind about receiving any form of marketing communications, you can unsubscribe at any time using the unsubscribe functionality in the communication you receive or by amending your profile accordingly. You may also be able to opt-out of push notifications at a device level (e.g. by way of your iOS settings). If you choose to unsubscribe from our marketing, we will keep a record of your preferences so that we don't bother you with unwanted marketing in future.

   • Feedback and reviews

     If you give us feedback we will use it to reply to your questions or queries, to provide customer support and resolve any problems with your Orders or with the Services. We may publish reviews that you send to us and we also analyse your feedback to improve and develop our Services and in order to enhance your experience. 

   2. Information that we collect automatically 

      When you access our Services, we may collect certain information automatically from your device such as your IP address, MAC address or device ID.

      • Activity Information

        We analyse your buying habits and how you interact with our Services so that we can suggest food options we think you would like to try. If you choose to share your geo-location with us, we may use this information to show you content that is local to you; this information will also help smooth the effective and speedy delivery of your Order. We may also provide you with customised content and advertisements based on your previous interactions with our Services and our knowledge of your preferences which we understand from your usage and buying history relating to the Services.

        We enable you to access your Order history so that you can easily reorder. We may also collect information about your interaction with our emails and other forms of communication. 

      • Cookies and similar technologies

        We may work with advertising affiliates that serve advertisements on our Services on the websites and services of third parties. Some of those networks use cookies which allow us to display advertisements that are personalised to your interests based upon your internet browsing activity.

        Like many websites and online services we use cookies and other technologies to maintain a record of your interaction with our Services. Cookies also help us to manage a range of features and content as well as to store searches and re-present your information at the point of Order. For further information about the types of cookies and similar technologies we use, why, and how you can control such technologies, please see our Cookie Policy.

   3. Information that we obtain from third party sources

      • Analytics reports and market research surveys

        We analyse information we collect from our third-party service providers (such as Google, Facebook, Amazon and other affiliates) to understand how you engage with our Services and advertisements (e.g. whether you have clicked on one of our advertisements). This helps us to understand your preferences and recommend you Services which are tailored to your interests. 

3. Who we share personal information with

   In delivering the Services to you, depending on the circumstances, we may share your personal information with the following entities:

   1. Companies within the Cromwells group of companies (which means our subsidiaries and affiliates, our ultimate holding company (if applicable) and its subsidiaries and affiliates either now or at any time in the future) - these companies act for us and process your personal information for the purposes set out in this Privacy Policy.
   2. Third parties who undertake various activities to promote and support our Services. This includes 3rd party customer support agents, website and application support and hosting providers, marketing service providers, eCRM partners, transaction SMS and email providers, potential delivery companies who deliver your Order to you, market research companies and payment processing providers which process payment card transactions - any of these third parties might be inside or outside your country of residence. We make every effort to ensure that your data is held within United Kingdom. 
   3. As mentioned in section 2 above, we may also share information with other companies operated by our Data Processor (ZPos Ltd) and third parties (for example, in the food, drink and entertainment sectors) so that they can contact you about goods or services which may interest you.
   4. If any part of our business enters into a joint venture, purchases another business or is sold to or merged with another business entity, your information may be disclosed or transferred to the target company, or new business partners or owners or their agents and advisors. In these circumstances we will always inform the relevant entities that they must only use your personal information for the purposes disclosed in this Privacy Policy. 
   5. Any law enforcement or regulatory body, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person.
   6. Any other person provided that we deem appropriate. We will not sell your personal information to external companies unless we have your permission or are required by law to do so.

4. Legal basis for processing personal information

   Our legal basis for collecting and using your personal information as described above will depend on the specific context in which we collect it.

   Our main reason for collecting and using your personal information is to perform our contract with you (i.e. to make sure you get your Order when you want it). However we will also use your personal information where it is in our legitimate business interests to do so (but only if our interests are not overridden by your data protection interests or your fundamental legal rights and freedoms). In some cases, we may have a legal obligation to collect personal information from you (e.g. in the event of legal proceedings) or we might need to process it or share it with others to "protect your vital interests" (this is legal speak for saving your life) or those of another person (e.g. in a case where another person's life is in danger). 

   If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (and we'll also explain the possible consequences of you not providing it). 

   Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

   If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the "How to contact us" below.

5. International data transfers

   We may transfer your personal information to countries other than the country in which you are resident. Cromwells currently only uses website servers that are located in the United Kingdom. Some of our providers may use non UK servers which means that when we collect your personal information they may process it in any of these countries.

   Whilst these countries may have data protection laws that are different to the laws of your country, you can rest assured that Cromwells takes care to implement appropriate safeguards to protect your personal information in those countries in accordance with this Privacy Policy. Some of the safeguards we rely on include, where appropriate, using the European Commission's approved standard contractual clauses with our suppliers, intra-group transfer agreements (so that we can safely transfer your data between any Cromwells branch we currently have, or may have in the future) and contracting with Privacy Shield certified companies in the United States, where this is appropriate.

6. Security

   We place great importance on keeping your personal information safe and secure. As such, we put in place appropriate technical and organisational measure/industry standard technology to protect it from unauthorised access and unlawful processing, accidental loss, destruction and damage. 

   The security measures we use are designed to provide a level of protection security appropriate to the risk of processing your personal information. Where you have chosen a password which allows you to access certain parts of the Services, you are responsible for keeping this password confidential. We advise you not to share your password with anyone and to use a unique password for our Services. We will not be liable for any unauthorised transactions entered into using your name and password.

7. Data retention

   Cromwells member's will retain your personal information where we have an ongoing legitimate business need to do so (for example, while you hold an account with us or to enable us to meet our legal, tax or accounting obligations). 

   If you object to us processing certain categories of your personal information (including in relation to receiving marketing communications from us), we will retain a record of your objection to the processing of your information so that we can continue to respect your wishes.

   We will destroy or permanently anonymise your personal information at the point that we no longer need to process it for our ongoing legitimate business needs or for any legal reason. If this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store it and isolate it from any further processing until deletion is possible.

8. Your data protection rights

   Cromwells respects your privacy and data protection rights. Below is a summary of your rights in respect of the personal information of yours which we(and our affiliates) handle: 

   • Cromwells provides you with the tools to access, review or update your personal information at any time through your account. If you wish to request deletion of your personal information, you can do so by contacting us using the contact details provided under the "How to contact us" heading below. We don't currently hold any data on you that you cannot already remove from the members area of this website.
   • You can object to processing of your personal information, ask us to restrict processing of your personal information or request that it be ported to a third party. Again, you can exercise these rights by contacting us using the contact details provided under the "How to contact us" heading below. 
   • You have the right to opt-out of receiving marketing communications we send you at any time. You can exercise this right by using the unsubscribe functionality in the communication you receive or by amending your profile accordingly. 
   • Similarly, if we collect and process your personal information on the basis of your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
   • You have the right to complain to a data protection supervisory authority about our collection and use of your personal information.

   We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

9. Links to third-party sites

   Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates or to any number of websites that may offer useful information to our visitors. We provide these links to you only as a convenience and the inclusion of any link does not imply endorsement of the relevant website by Cromwells. If you follow a link to any of these websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for these policies or those linked websites. Please check these policies before you submit any personal information to such websites.

10. Updates to this Privacy Policy

    We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws. 

    We encourage you to periodically review this page for the latest information on our privacy practices.

11. How to contact us

    If you have any questions or concerns about this Privacy Policy or otherwise, please contact the manager of our shop:

    • By email at:
      • [email protected]
    • By writing to us at: 
      • FAO: The Manager
        Ref: Privacy Policy
        Cromwells
        6 Malvern Road
        Powick
        Worcester
        Worcestershire
        United Kingdom
        WR2 4QP

    The controller of your personal information is the Cromwells member's entity in the country in which you use our Services.

Your contact details may be shared with our service provider and between our other companies for reasons not limited to that of fraud prevention and marketing. Your payment details are not accessible by Cromwells or our service providers and are kept completely private; they are not stored on our systems.