Privacy & Data Protection Policy

Who we are

1.1. Falk Copper Cookware is a trading style of Europe Copper Limited.

1.2. Europe Copper Limited is a private company registered in England and Wales with the company number 08479418. Our registered office is at 483 Green Lanes, London, N13 4BS in the United Kingdom.

1.3. Europe Copper is registered as a data controller with the Information Commissioners Office in accordance with the Data Protection Act 2018.

1.4. We are committed to the providing excellent quality products and service to our customers and this commitment extends to how we look after your personal information.

1.5. If you have any questions about how we look after your personal data, you can contact us:

• In writing, at our office address above. Please mark your letter for the attention of the Data Protection Officer
• By email to this address: dpo@falkcopperpans.com
• By telephone on +44 (0)203 637 2890

The information we need and how we use it

2.1. When you place an order with Falk Copper Cookware via our website (www.falkcoppercookware.com), over the telephone, or by post, as well as the items you have selected, we collect personal information about you to enable us to fulfil your order.

2.2. The information that you share with us may be used to keep you in touch with our latest promotional offers, new products and your account information. If you would prefer us not to contact you by any of these methods, or wish to change your preferences at any time, simply let us know.

2.3. We require your name, delivery address, e-mail address (if your order is placed online), credit/debit card number and card expiry date and the three or four-digit security code from the back of your card. We need these details to process your order and on rare occasions to inform you of any delays or problems with items in your order. Without this information, we will not be able to process your request or notify you of acceptance of your order. We request a contact telephone number too so that we may contact you urgently if there is a problem your order or its delivery. We may, unless you advise us otherwise, pass this contact number to our couriers or other agents in case they need to contact you to arrange the processing or delivery.

2.4. When you register with us the information that you share will allow us to contact you with notifications of special offers, promotions and other correspondence from us via email a few times a year. You are always in complete control of how we can contact you for marketing purposes. If you don’t want to receive our marketing communications, please let us know at the time of ordering. When creating an account online, if you leave the box unticked you will not receive email marketing communications from us. After you have registered your online account with Falk Copper Cookware you can manage your preferences for marketing communications including the frequency with which we will send them online. You can also opt-out of receiving emails by using the unsubscribe link at the bottom of any such email correspondence.

2.5. How we use your personal data:

• To enable you to place orders for Falk Copper Cookware products and services
• To fulfil those orders sending you the products and services you have purchased from Falk Copper Cookware and enable us to communicate with you about them
• To manage the account you have registered with us including your preferences for marketing communications
• To improve the range of products offers and associated products we can offer you and to help identify new products and services in the future
• To personalise the communications, you receive from us about Falk Copper Cookware products and special offers and promotions including our sales
• To verify your identity
• To detect and prevent fraud and other illegal activities (and to assist regulators, trade bodies and law enforcement agencies in relation to the same)
• To carry out research to better understand your views on our products and services
• To allow you to continue enjoying our customer service
• To comply with the law

2.6. Our lawful basis for processing your personal data - When fulfilling any orders, you place with Falk Copper Cookware we will process your personal data we rely on the lawful basis of contract. When keeping in touch with you via our marketing communications we will process your personal data we rely on the lawful basis of Legitimate Interest.

2.7. Falk Copper Cookware’s "Legitimate Interests" means the interests of our company in conducting and managing our business to enable us to give you the best products and services, and the best and most secure experience whether via our website or our contact centre.

2.8. When we process your personal information for our legitimate interests, we make sure to consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. This is a fair process and our legitimate business interests do not automatically override your interests - we will not use your personal data for activities where our interests are overridden by the impact on you (unless you have requested us to do so or are otherwise required or permitted to by law).

2.8. For example, we have an interest in marketing our products and services to you, and making sure our marketing is relevant and timely for you. Therefore, we may process your information to send you marketing that is tailored to your interests. It can also apply to processing that is in your interests as well. For example, we may process your information to protect you against fraud when transacting on our website, and to ensure our websites and systems where your personal data is stored are secure.

2.10. We may receive your data from third party partners, who will have explained that your information, such personal data will be used for targeted advertising. These organisations will have a relationship with you or may use your data where they have a lawful reason, which may include these organisations' own legitimate interest.

2.11. In addition to sending you marketing communications, we rely on our legitimate interests to process your personal data so that we can:

• Improve our existing product range, associated products and services, and develop new ones
• Provide you with a quality customer service experience
• Protect you, our employees and our business
• Understand your likes and dislikes, what products you want to hear about and how best to contact you to inform you about them
• Manage insurance claims made by our customers
• Taking legal action against any party in breach of its obligations to Europe Copper Limited, and handling any legal claims or regulatory enforcement actions taken against Europe Copper Limited

2.12. Your use of this website signifies your consent to the collection, processing and use of personal information by us for the purpose of administering and dealing with your order or account, market research, processing your payments, credit reference checking and fraud detection, and for marketing purposes as outlined above. Any changes to our privacy policy will be posted on this site so that you may ensure that you are fully informed of your rights and can notify us of any changes to your preferences.

Security of your information

3.1. Our site uses secure server software to protect your information whenever you place an order or access your account information. This software encrypts all information you input before it is transferred, to minimise the risk of the data being intercepted before it is received by our systems. We also follow a tight security procedure as required under UK Data Protection Legislation (the Data Protection Act 2018) to protect the information that we store about you from unauthorised access. We will never share your email address or telephone numbers with any retail partners.

3.2. Internal Confidentiality Within Falk Copper Cookware - we protect your privacy in three ways:

• Access to customer account information is limited to those who need access for the performance of their job
• We use full login and password controls on our order processing system
• Confidentiality and database access controls are reviewed periodically and updated as required to further protect your personal data

Your rights

4.1. If, for any reason, you are unsure about the personal and account information we are holding in your name, please contact us. We will happily review your account and update the records if required. You can contact us by email, telephone or letter. Alternatively, this information can be checked and reviewed once you have signed in to your account on our website. You have several rights under data protection laws; these are summarised below.

4.2. Your right to be informed - We need to be clear with you about how we process your personal data. We give this with clarity in this Privacy Policy, which we will commit to reviewing at least once a year and will update with any changes to the way we process your data. You will always be able to find a copy of our privacy policy on our website or you can contact us and we will send you a copy.

4.3. Your right of access - At any time, you can request access to the personal data we hold about you and your purchases with Falk Copper Cookware by writing to our office address, calling us on +44 (0)203 637 2890 or emailing us at dpo@falkcopperpans.com. To process your request, we will contact you to provide verification so that we can be sure we are releasing your personal data to the right person. We will aim to process your request within one month of receiving it. However, if your request is particularly complex or we have received numerous requests, your request may take a little longer to a maximum of three months from receipt of your request. If we do need this additional time, we will write to you within the first month to advise of reason for the extension. We can provide you with a copy of your personal data in electronic format or hard copy. If we consider the frequency of your requests is unreasonable, we may refuse to comply with your request. In those circumstances, we would notify you of your right to complain to the Information Commissioner's Office.

4.4. Your right to rectification - We will always try to ensure that our records are as accurate and up to date as possible. We ask for your help to enable us to do this. If you think that the information we hold about you is inaccurate or incomplete we would welcome your feedback. Please contact us by calling us on +44 (0)203 637 2890 or emailing via our online form at www.falkcoppercookware.com/contact.

4.5. Your right to erasure (also known as your right to be forgotten) - Your right to erasure is also known as your right be forgotten. You can ask us to delete your personal data; however, this is not an absolute right. We can refuse to erase personal data which we need to keep (i) to comply with a legal obligation (for instance, we are required by HMRC to keep certain personal data for up to 6 years for VAT reporting purposes); (ii) in relation to the exercise or defence of any legal claims (iii) where your account has been involved in fraudulent activity. When you ask us to erase your personal data from our records, we will assume that you do not want to hear from us again. To ensure that we do not send you any special offers in the future, we will retain just enough of your personal data solely for suppression purposes.

4.6. Other than as described above, we will always comply with your request. Where there is no compelling reason for its continued processing the information will be deleted in line with your request.

4.7. Your right to restrict processing - Some customers would prefer not to receive any marketing communications from us but would still like to order our products - they wish to restrict the processing of their personal information they have shared with us to the fulfilment of orders and provision of customer service information. This is not a problem and you can update your marketing preferences by calling us on +44 (0)203 637 2890 or emailing via our online form at www.falkcoppercookware.com/contact.

4.8. Your right to object and your rights related to automated decision making and profiling - Here at Falk Copper Cookware we work hard to personalise your experience with us as a customer to ensure that the offers and other information for example new product launches we send you are interesting, timely and relevant. To do this we may look at your previous purchases, any reviews you have left and content you have downloaded or shared from our website or social media pages. This enables us to build a profile of the products within our range that we believe from the actions you have taken that you are most likely to buy or recommend. This is known as ‘profiling’. We may determine which products and offers to contact you about by using automated decision-making processes. If you would like us to stop processing your personal data for marketing purposes simply let us know by calling us on +44 (0)203 637 2890 or emailing us via our online form at www.falkcoppercookware.com/contact. Please be aware that if you ask us to stop profiling your personal data we will no longer be able to send you the offers and content that relate to the products you enjoy the most.

When we share your personal data

5.1. So that we can provide you with our products and services, we need to share some of your personal data with core service providers including the courier companies we use to deliver our products to you; banks and clearing houses to process your payments; companies we use to carry out fraud protection; and IT services providers.

5.2. We will make sure that your personal data remains secure:

• Every external company we work with is required to have a contract with us which clearly describes the data we are sharing with them and the purposes for which they can use your personal data. In addition, we set out our expectations about the way in which they keep your personal data secure and holds them fully responsible for meeting those expectations
• We will only send to our service providers the personal data that they need to fulfil their service to us

5.3. With regulators and law enforcement agencies when required to do so by law - We are required to co-operate with regulators (like the Information Commissioner's Office or HMRC) and law enforcement agencies (like the police or the Serious Fraud Office) in every country we operate in. Although it does not happen often, regulators and law enforcement agencies can require us to share information with them as part of an investigation; this may include your personal data. We would have to disclose your personal data where we believe that disclosure is reasonably necessary to comply with the regulator or crime enforcement agency's demand. When we think it is reasonably necessary to protect you or us. Occasionally businesses are subject to attempted criminal activities; this can affect both us and you. We will take all reasonable steps to protect you and our business but sometimes we may need to share your personal data where we think it is reasonably necessary to:

• Detect, monitor, investigate or prevent any suspected illegal activities, fraud or security issues
• Enforce our terms and conditions and to protect your and our rights and property
• Investigate and defend any third-party claims or allegations