Privacy Policy

Boudican 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, www.boudican.com 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. By accepting our Terms of Use, you are confirming that you have read and understand this policy, including how and why we use your information and consenting to the practices described in this policy. If you don’t want us to collect or process your personal information in the ways described in this policy, you shouldn’t use the Services. We are not responsible for the content or the privacy policies or practices of any of our members, third-party websites, or third-party apps.

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 Site;
“Cookie”	means a small text file placed on your computer or device by Our Site when you visit Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and
“Cookie Law”	means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
“Buyer”	means a User who makes a purchase on Our Marketplace;
“Our Site”	means this website, www.boudican.com;
“Payment Service”	means the payment service provided by Stripe Payments Ltd;
“Seller”	means a User who sells on Our Marketplace;
“We/Us/Our”	means Boudican Limited, a limited company registered in England under company number 12159114, whose registered address is `27 Old Gloucester Street`, London, United Kingdom, WC1N `3AX`.

2.Information About Us

Our Site is owned and operated by Boudican Limited, a Limited company registered in England under company number 12159114, whose registered address is 27 Old Gloucester Street, London, United Kingdom, WC1N 3AX.

3.What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. 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 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 General Data Protection Regulation (EU Regulation 2016/679) (the “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 My Rights?

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

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 Part 15.
The right to access the personal data we hold about you. Part 13 will tell you how to do this.
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 Part 15 to find out more.
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 Please contact us using the details in Part 15 to find out more.
The right to restrict (i.e. prevent) the processing of your personal data.
The right to object to us using your personal data for a particular purpose or purposes.
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.
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.
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 Part 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 Part 15.

6. What Data Do You Collect and How?

Depending upon your use of our Site, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. Please also see Part 14 for more information about our use of Cookies and similar technologies and our Cookie Policyhttps://www.boudican.com/cookie-policy/

Data Collected	How we Collect the Data
Identity Information including name	Registration, Account Setup, Service Usage
Contact information including address, email address, telephone number	Registration, Account Setup, Service Usage
Business information including business name Shop Name, Name of the organic certificate issuer, Certificate number	Registration
Payment information including card details	Service Usage
Profile information including preferences, login details, location, purchase history	Account, Activity, Service Usage
Technical information including IP address, browser type and version, operating system	Automated Information
Data from third parties (optional) including technical information, profile information	Registration
Analytics Information including aggregated usage, performance data, errors, use frequencies.	Service Usage

7. How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:

What we Do	What Data we Use	our Lawful Basis
Registering you on our Site.	Buyer only require email address. We capture additional information for the sellers, such as a business name, Shop Name, Name of the organic certificate issuer, Certificate number, Address, contact details.	Verify ownership of an account, to mitigate fraud and abuse on the platform, or to complete a transaction as a buyer or seller.
Providing and managing your Account, profile and service usage	Email address. Depending on which services you choose to use, additional information, such as date you joined; ratings, reviews and related photos for items you purchased or sold; your profile information; items you listed for sale; your shop pages and policies; your Favourites, followers, and those you follow; sold item listings and the number of items sold; comments you post in our community spaces; and information you decide to share via social networks.	For identification and authentication, And for general research and aggregate reporting and to provide you a particular service.
Personalising and tailoring your experience on our Site.	Technical information including IP address, browser type and version, operating system; Profile information including preferences, login details, location, purchase history	Provide features and to improve and customise the Services
Administering our Site.	Your IP address or unique device identifier, cookies, and data about which pages you visit and how you interact with those pages	Allow us to operate and provide the Services
Administering our business.	Analytics Information including aggregated usage, performance data, errors, use frequencies.	We need analytics to ensure site functionality and improve the Services
Shopping and supplying products to you.	Contact information including address, email address, telephone number	We need a physical postal address if you are buying something on the Site for delivery
Managing payments for products and services.	Billing and payment information (including billing contact name, address, telephone number, credit card information), a telephone number, and/or a physical postal address	Verify your identity, provide service to you, and comply with applicable law.
Personalising and tailoring our products and services for you.	Profile information including preferences, login details, location, purchase history.	Provide features and to improve and customise the Services.
Communicating with you.	Email address	Send purchase receipts and other notifications to maintain and provide our Services.
Keeping our Services Safe and Secure	Name and email address	To enhance protection against spam, harassment, intellectual property infringement, crime, and security risks of all kind.

With your permission and where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone and text message with information, news, and offers on our products and 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.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

8. How Long Will You Keep My 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 for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Type of Data	How Long we Keep It
Identity Information including name	Boudican will retain your information only for as long as is necessary for the purposes set out in this policy, for as long as your account is active, as described in this policy, or as needed to provide the Services to you. Boudican sellers may also be required to retain and use your information in order to comply with their own legal obligations.
Contact information including address, email address, telephone number	Boudican will retain your information only for as long as is necessary for the purposes set out in this policy, for as long as your account is active, as described in this policy, or as needed to provide the Services to you. Boudican sellers may also be required to retain and use your information in order to comply with their own legal obligations.
Business information including business name Shop Name, Name of the organic certificate issuer, Certificate number	Boudican will retain your information only for as long as is necessary for the purposes set out in this policy, for as long as your account is active, as described in this policy, or as needed to provide the Services to you.
Profile information including preferences, login details, location, purchase history	Boudican will retain your information only for as long as is necessary for the purposes set out in this policy, for as long as your account is active, as described in this policy, or as needed to provide the Services to you. Boudican sellers may also be required to retain and use your information in order to comply with their own legal obligations.
Technical information including IP address, browser type and version, operating system	As long as is necessary
Data from third parties (optional) including technical information, profile information	As long as is necessary

9.How and Where Do You Store or Transfer My Personal Data?

We will only store or transfer your personal data 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 will be fully protected under the Data Protection Legislation, GDPR, and/or to equivalent standards by law.

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;
We follow generally accepted standards to protect the personal information submitted to us, both during transmission and after it is received. Your account information is protected by a password. It is important that you protect against unauthorised access to your account and information by choosing your password carefully and by keeping your password and computer secure, such as by signing out after using the Services. If you have any questions about the security of your personal information, you can contact us at legal@Boudican.com.

10. Do You Share My Personal Data?

We respect your privacy. Boudican will not disclose your name, email address or other personal information to third parties without your consent, except as specified in this policy.

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 ways 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.

We use the following third parties to supply certain services:

Recipient	Activity Carried Out	Sector	Location
Amazon Web Services	Server hosting	Hosting	EU (London)
Stripe Payments Ltd	Online payments	Financial Services	UK

If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.

If any personal data is transferred outside of the EEA, 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 Part 9.

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.

As part of the buying and selling process, Boudican will facilitate the sharing of information between the two members involved in the transaction, such as the other Boudican member’s delivery address and payment status. This may also involve us sharing your information with some of our third-party partners such as our delivery and payment partners to enable us to provide the service to you. Such partners will process your personal information in accordance with their own privacy policies. These partners, not Boudican, are responsible for the protection of personal information under their control. By making a sale or a purchase on Boudican, you are directing us to share your information in this way. Since this is an important part of the Services we provide, we need to do this in order to perform our obligations under our Terms of Use.

Boudican may share demographic information with business partners, but it will be aggregated and de-personalised so that personal information is not revealed.

Boudican also needs to engage third-party companies and individuals (such as research companies, and analytics and security providers) to help us operate, provide, and market the Services. These third parties have only limited access to your information, may use your information only to perform these tasks on our behalf, and are obligated to Boudican not to disclose or use your information for other purposes.

Third-party plug-ins also may collect information about your use of the Site. For example, when you load a page on Boudican that has a social plug-in from a third-party site or service, such as a “Like” or “Send” button, you are also loading content from that third-party site. That site may request cookies directly from your browser. These interactions are subject to the privacy policy of the third-party site.

11. How Can I Control My Personal Data?

- 11.1 In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via our Site, you may be given options to restrict our use of your personal 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 and by managing your Account).
- 11.2 You may also wish to sign up to 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 receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
- 11.3 We offer several features that allow members to connect and communicate in public or semi-public spaces, such as comments and Q&A, which are a part of the Boudican Community space. You don’t have to use these features, but if you do, please use common sense and good judgment when posting in these community spaces or sharing your personal information with others through the Services. Be aware that any personal information that you choose to submit there can be read, collected, or used by others, or could be used to send unsolicited messages to you.

12. Can I Withhold Information?

You may access our Site without providing any personal 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.

You may restrict our use of Cookies. For more information, see Part 14 and our Cookie Policyhttps://www.boudican.com/cookie-policy/

13. How Can I Access My 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 (where any such personal data is held). 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 Part 15. To make this as easy as possible for you, a Contact us Form is available for you to use. You do not have to use this form, but 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.

we will respond to your subject access request within 3 weeks and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

14. How Do You Use 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.

By using our Site, you may also receive certain third-party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. Third party Cookies are used on Our Site for performance improvement, analytics, advertising and marketing Services. For more details, please refer to the table below. These Cookies are not integral to the functioning of our Site and your use and experience of our Site will not be impaired by refusing consent to them.

All Cookies used by and on our Site are used in accordance with 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. You will be given the opportunity to allow or deny different categories of Cookie that We use.

Certain features of our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. 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, 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.

The following first-party Cookies may be placed on your computer or device:

Name of Cookie	Purpose & Type	Expiration
cookie_notice_accepted	To track privacy policy acceptance	1 year
tk_ai	Seller dashboard usage	Session
woocommerce_cart_hash	Allow the site to keep track of what users add to their shopping cart and their preferences.	Session
woocommerce_items_in_cart	Allow the site to keep track of what users add to their shopping cart and their preferences.	Session
wp_woocommerce_session_	Session tracking	3 days
__cfduid	Use to override any security restrictions based on the IP address the visitor is coming from. It does not correspond to any user id in the web application, nor does the cookie store any personally identifiable information.	1 year
wordpress_logged_in_*	Allows users to remain logged into the site	Session
wordpress_sec_*	Current “logged in” status	Session

and the following third-party Cookies may be placed on your computer or device:

Name of Cookie	Purpose & Type	Provider	Expiration
_fbp	Targeting/advertising	Facebook	3 months
_hjid	Performance	Hotjar	1 year

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.

The analytics service(s) used by our Site use(s) Cookies to gather the required information. 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) the following Cookies:

Name of Cookie	Purpose & Type	Provider	Expiration
_ga ,gid, gat	Google Analytics (including related advertising services)	Google	1 Day to 13 Months
_hjIncludedInSample	Web analytics functionality and services	Hotjar	Session

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.

For more details, please refer to our Cookie Policyhttps://www.boudican.com/cookie-policy/

15. How Do I Contact You?

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:
Telephone: 02070973821
Email: legal@boudican.com
Post: 27 Old Gloucester Street, London, WC1N 3AX.

16. Changes to this Privacy Policy

We may change this Privacy Notice 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 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.

This Privacy Policy was last updated on 26/10/2019.

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