CUPPION LTD: PRIVACY POLICY

What this policy applies to

This privacy policy sets out how Cuppion Ltd uses and protects your personal data. This includes personal data collected in connection with business-to-business purchases made through our website.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).
Where we offer goods or services to individuals located in the European Economic Area (EEA), we also comply with the EU General Data Protection Regulation (EU GDPR).

This privacy policy relates to your use of our website only.

Personal data we collect about you

We will collect and use the following personal data about you:

your name, address and contact information, including email address, telephone number and company details
any delivery addresses specified for your order
your billing information, transaction and payment card or other payment method information
bank account and payment details – Payment card details are processed securely by our third-party payment service providers. We do not store full payment card numbers or security codes.
details of any information, feedback or other matters you give to us by phone, email, post or via social media
your account details, such as username and login details
your activities on, and use of, our website
information about the services we provide to you
your purchase history and saved items

You must provide this personal data to use our website and the services on it, unless we tell you that you have a choice.

Sometimes you can choose if you want to give us your personal data and let us use it. Where that is the case, we will tell you and give you the choice before you give the personal data to us. We will also tell you whether declining to share that personal data will have any effect on your use of the website or any services on it.

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.\ If you do not provide the personal data required to process your order, we may be unable to enter into or perform a contract with you.

How your personal data is collected

We collect personal data from you:

directly, when you enter or send us information, such as when you register with us, contact us (including via email), send us feedback, purchase products or services via our website, and
indirectly, such as your browsing activity while on our website; we will collect information indirectly using the technologies explained in the section on ‘Cookies’ below

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason, eg:

where you have given consent
to comply with our legal and regulatory obligations
for the performance of a contract with you or to take steps at your request before entering into a contract, or
for our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

The table below explains what we use your personal data for and why.

What we use your personal data for	Our reasons
Creating and managing your account with us	To perform our contract with you or to take steps at your request before entering into a contract
Providing products to you	To perform our contract with you or to take steps at your request before entering into a contract
Retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive or to check our website is working as intended	Depending on the circumstances: —your consent as gathered by the separate cookies tool on our website —see ‘Cookies’ below —where we are not required to obtain your consent and do not do so, for our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price If you have provided such a consent you may withdraw it at any time (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn)
Communications with you not related to marketing, including about changes to our terms or policies or changes to the products or other important notices	Depending on the circumstances: —to comply with our legal and regulatory obligations —in other cases, for our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price
Statistical analysis to help us understand our customer base	For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price
Updating and enhancing customer records	Depending on the circumstances: —to perform our contract with you or to take steps at your request before entering into a contract —to comply with our legal and regulatory obligations —where neither of the above apply, for our legitimate interests, eg making sure that we can keep in touch with our customers about existing orders and new products
Marketing our services to existing and former customers	For our legitimate interests, ie to promote our business to existing and former customers See ‘Marketing’ below for further information
To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency In such cases information will be anonymised where possible and only shared where necessary	Depending on the circumstances: —to comply with our legal and regulatory obligations —in other cases, for our legitimate interests, ie to protect, realise or grow the value in our business and assets

How and why we use your personal data—in more detail

More details about how we use your personal data and why are set out in the table below.

Purpose	Processing operation	Lawful basis relied on under the UK GDPR	Relevant categories of personal data
Communications with you not related to marketing, including about changes to our terms or policies or changes to the products or other important notices	Addressing and sending communications to you as required by data protection laws, ie: —the UK GDPR or Data Protection Act 2018	Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b))	—your name, address and contact information, including email address and telephone number, and company details —your account details (username)
	Addressing and sending communications to you as required	Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b))
	Addressing and sending communications to you about changes to our terms or policies or changes to the products or other important notices (other than those addressed above)	Our legitimate interests (Article 6(1)(f)), which is to be as efficient as we can so we can deliver the best service to you	—your name, address and contact information, including email address and telephone number and company details —your account details (username)

Marketing

We will use your personal data to send you updates (by email, text message, telephone or post) about our products, including exclusive offers, promotions or new products.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by:

contacting us.
using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts.

We may ask you to confirm or update your marketing preferences if you ask us to provide further products in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never sell share it with other organisations for marketing purposes.

For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.

Who we share your personal data with

We routinely share personal data with:

third parties we use to help deliver our products to you, eg payment service providers, warehouses and delivery companies
These third parties may include:
payment providers (e.g. Revolut, PayPal or equivalent)
courier and logistics providers(e.g. DPD,)
cloud hosting and IT infrastructure providers
analytics providers (e.g. Google Analytics or equivalent)
other third parties we use to help us run our business, eg marketing agencies or website hosts and website analytics providers
our bank

We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on them to ensure they can only use your personal data to provide services to us and to you.

We or the third parties mentioned above occasionally also share personal data with:

our and their external auditors, eg in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations
our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations

8.Who we share your personal data with—in more detail
Other than as set out in section 7 above, we do not share your personal data with third parties unless required by law or permitted under applicable data protection legislation.

How long your personal data will be kept

We will not keep your personal data for longer than we need it for the purpose for which it is used.

Different retention periods apply for different types of personal data.

We retain personal data only for as long as necessary, including:

Order and transaction data: up to 6–7 years for tax and accounting purposes
Customer account data: for as long as the account remains active and for a reasonable period thereafter
Marketing data: until you withdraw consent or opt out

Transferring your personal data out of the UK

The UK and other countries outside the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.

It is sometimes necessary for us to transfer your personal data to countries outside the UK. In those cases we will comply with applicable UK laws designed to ensure the privacy of your personal data.

We will transfer your personal data to:

our service providers located outside the UK, and

Under data protection laws, we can only transfer your personal data to a country outside the UK where:

in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available here.
there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you, or
a specific exception applies under relevant data protection law

Where we transfer your personal data outside the UK we do so on the basis of an adequacy regulation or (where this is not available) legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.

Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.

Where personal data is subject to the EU GDPR, we rely on:

European Commission adequacy decisions, or
Standard Contractual Clauses approved by the European Commission

Cookies

A cookie is a small text file which is placed onto your device (eg computer, smartphone or other electronic device) when you use our website. We use cookies on our website. They help us recognise you and your device and store some information about your preferences or past actions.

For further information on cookies, our use of cookies, when we will request your consent before placing them and how to disable them, please see our Cookie Policy.

Your rights

You generally have the following rights, which you can usually exercise free of charge:

Access to a copy of your personal data	The right to be provided with a copy of your personal data
Correction (also known as rectification)	The right to require us to correct any mistakes in your personal data
Erasure (also known as the right to be forgotten)	The right to require us to delete your personal data—in certain situations
Restriction of use	The right to require us to restrict use of your personal data in certain circumstances, eg if you contest the accuracy of the data
Data portability	The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object to use	The right to object: —at any time to your personal data being used for direct marketing (including profiling) —in certain other situations to our continued use of your personal data, eg where we use your personal data for our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims
The right to withdraw consents	If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.

If you would like to exercise any of those rights, please email, call or write to us—see below: ‘How to contact us’. When contacting us please:

provide enough information to identify yourself (eg your full name, address and customer or matter reference number) and any additional identity information we may reasonably request from you, and
let us know which right(s) you want to exercise and the information to which your request relates

Where we rely on legitimate interests, you have the right to object to such processing at any time.

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to complain

Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with:

the Information Commissioner

The UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.

If you are located in the EEA, you also have the right to lodge a complaint with your local data protection supervisory authority.

Changes to this privacy policy

We may change this privacy policy from time to time—when we make significant changes we will take steps to inform you.

How to contact us

You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

For the purposes of applicable data protection law, Cuppion Ltd is the “data controller” of your personal data.

Here is a fully rewritten, regulator-ready privacy policy aligned with UK GDPR, EU GDPR, and ePrivacy/PECR requirements, written clearly and professionally while covering your eCommerce use case.

Privacy Policy

Who We Are

This privacy policy explains how Cuppion Ltd (“we”, “us”, “our”) collects, uses, and protects your personal data when you use our website or purchase products from us.

For the purposes of applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR) and, where applicable, the EU General Data Protection Regulation (EU GDPR), Cuppion Ltd is the data controller of your personal data.

If you are located in the European Economic Area (EEA), this policy also applies to you where we offer goods or services to you.

What This Policy Covers

This policy applies to personal data we collect in connection with:

Use of our website
Business-to-business and business-to-customer purchases
Communications with us

Personal Data We Collect

We may collect and process the following categories of personal data:

Identity Data: name, company name
Contact Data: billing address, delivery address, email address, telephone number
Account Data: username, password, account preferences
Transaction Data: order details, purchase history, payment information
Payment Data: billing details and limited payment information
Technical Data: IP address, browser type, device information
Usage Data: information about how you use our website
Communications Data: correspondence, feedback, and enquiries

Important: Payment card details are processed securely by our third-party payment providers. We do not store full card numbers or security codes.

If you do not provide certain required personal data, we may be unable to process your order or provide our services.

How We Collect Your Data

We collect personal data:

Directly from you when you create an account, place an order, or contact us
Automatically through cookies and similar technologies when you use our website

Legal Bases for Processing

We only process your personal data where permitted by law. This includes:

Contract – to perform a contract with you (e.g. fulfilling orders)
Legal obligation – to comply with laws (e.g. tax and accounting)
Legitimate interests – to operate and improve our business
Consent – where required (e.g. certain marketing or cookies)

How We Use Your Personal Data

We use your personal data to:

Create and manage your account
Process and deliver your orders
Communicate with you about your orders or important updates
Improve our website and services
Prevent fraud and ensure security
Comply with legal obligations
Send marketing communications (where permitted)

We only use your data for the purposes for which it was collected unless reasonably necessary for a compatible purpose.

Marketing

We may send you marketing communications about our products and services where permitted by law, including:

Where you have provided consent, or
Where you are an existing customer and we rely on the “soft opt-in” under applicable ePrivacy laws

You can opt out at any time by:

Clicking “unsubscribe” in emails
Replying “STOP” to text messages
Contacting us directly

We will never sell your personal data to third parties for marketing purposes.

Who We Share Your Data With

We may share your personal data with trusted third parties, including:

Payment service providers
Delivery and logistics companies
IT and hosting providers
Analytics providers
Professional advisers (legal, accounting)
Regulators and authorities where required

We ensure all third parties respect your data and process it in accordance with the law.

International Transfers

Your personal data may be transferred outside the UK or EEA.

Where this happens, we ensure appropriate safeguards are in place, such as:

Adequacy decisions
Standard Contractual Clauses
UK International Data Transfer Agreements (IDTA)

Data Retention

We retain your personal data only as long as necessary, including:

Order and transaction data: up to 6–7 years (legal/tax requirements)
Account data: while your account is active and for a reasonable period after
Marketing data: until you opt out or withdraw consent

Cookies

We use cookies and similar technologies to:

Enable website functionality
Improve user experience
Analyse website traffic

For full details, see our Cookie Policy.

Your Rights

You have the following rights under data protection law:

Access your personal data
Correct inaccurate data
Request deletion (“right to be forgotten”)
Restrict processing
Data portability
Object to processing (including marketing)
Withdraw consent at any time

To exercise your rights, please contact us using the details below.

Automated Decision-Making

We do not use automated decision-making or profiling that produces legal or similarly significant effects.

Data Security

We implement appropriate technical and organisational measures to protect your personal data from:

Unauthorised access
Loss or misuse

We also have procedures to deal with suspected data breaches and will notify you and regulators where required.

Complaints

If you have concerns about how we use your data, please contact us first.

You also have the right to lodge a complaint with:

The UK Information Commissioner’s Office (ICO), or
Your local EU data protection authority (if applicable)

Changes to This Policy

We may update this policy from time to time. Where changes are significant, we will notify you.

Contact Us

If you have any questions or wish to exercise your rights, contact us at:

Cuppion Ltd
Email: [Insert Email Address]
Address: [Insert Registered Address]
Phone: [Insert Contact Number]

(Optional – Only If Applicable) EU Representative

If you are required to appoint one:

We have appointed an EU representative in accordance with Article 27 EU GDPR:
[Insert Name and Contact Details]

Final Note

This version is:

Legally aligned with UK GDPR + EU GDPR
Covers eCommerce risks (payments, shipping, marketing)
Written in a clear, regulator-friendly format

Cookie Policy

What Are Cookies?

Cookies are small text files placed on your device (computer, smartphone, or other electronic device) when you visit our website. They help us recognise your device and store information about your preferences or past actions.

How We Use Cookies

We use cookies to:

Ensure our website functions properly
Improve performance and user experience
Analyse how visitors use our website
Support security and fraud prevention
Deliver relevant marketing (where permitted)

Types of Cookies We Use

Strictly Necessary Cookies

These cookies are essential for the operation of our website and cannot be switched off. They include, for example:

Shopping cart functionality
Account login
Security and fraud prevention

Legal basis: Legitimate interests (or performance of a contract)

Analytics Cookies

These cookies help us understand how visitors use our website so we can improve it.

Examples may include tools such as:

Google Analytics (or similar providers)

Legal basis: Consent

Functionality Cookies

These cookies allow our website to remember choices you make (such as language or region).

Legal basis: Consent

Marketing Cookies

These cookies track your browsing activity to help deliver relevant advertising.

They may be set by:

Advertising networks
Social media platforms

Legal basis: Consent

Third-Party Cookies

Some cookies are placed by third parties on our behalf. These may include:

Analytics providers
Payment processors
Embedded content providers (e.g. video or social media platforms)

These third parties may process your personal data in accordance with their own privacy policies.

How to Manage Cookies

When you first visit our website, you will be asked to consent to non-essential cookies via our cookie banner.

You can:

Accept all cookies
Reject non-essential cookies
Manage your preferences

You can also control cookies through your browser settings. However, disabling certain cookies may affect website functionality.

How Long Cookies Are Stored

Cookies may be stored for different periods:

Session cookies: deleted when you close your browser
Persistent cookies: remain on your device until they expire or are deleted

Specific durations depend on the cookie type and provider.

Changes to This Cookie Policy

We may update this policy from time to time. Any changes will be posted on this page.

15. How to contact us

Our contact details are shown below:

Address: 24-28 Brockenhurst Road, Ascot, England, SL5 9DL.

Email: [email protected]

Telephone: 0330 043 4165