Privacy Policy
Privacy Policy
Welcome to the Peregrine Trading Limited privacy notice.
Peregrine Trading Limited respects your privacy and is committed to protecting your personal data. This privacy notice informs you as to how we use your personal data when you visit our website and tells you about your privacy rights and how the law protects you.
Please use the Glossary to understand the meaning of some of the terms used in this privacy notice.
- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURES OF YOUR PERSONAL DATA
- INTERNATIONAL DATA HANDLING
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS & WITHDRAWAL OF CONSENT
- GLOSSARY
IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this privacy notice
This privacy notice aims to give you information on how Peregrine Trading Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product or take part in a competition.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Data Controller
Peregrine Trading Limited, trading online as www.seggiano.com or, is the controller and responsible for your personal data (collectively referred to as “COMPANY”, “we”, “us” or “our” in this privacy notice).
Peregrine Trading Limited is the entity responsible for your personal data when you purchase a product from us, sign up to our newsletter or enter a competition.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Contact details
Full name of legal entity: Peregrine Trading Limited Name & title of DPO: David Harrison MD
Email address: [email protected]
Postal address: 3 Wedmore Street, London, N19 4RU Telephone number: 0207 272 5588
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and our duty to inform you of changes
This version was last updated on 13th June 2023 and historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
Our website does include links to third-party websites, plug-ins and applications.
THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use and store different kinds of personal data about you which we have grouped together follows:
If you make a purchase from our online shop or enter a competition, we may collect the following information:
- Identity Data includes: first name, last name, username or similar identifier, title.
- Contact Data includes: billing address, delivery address, email address and telephone numbers.
- Financial Data includes: bank account and payment card details.
- Transaction Data includes: details about payments to and from you and other details of products you have purchased from us.
- Profile Data includes: your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
If you visit our website and if you confirm acceptance of our cookies policy we may collect the following information:
- Technical Data includes: internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Usage Data includes: information about how you use our website, products and services.
If you confirm that you would like us to send you offers and news about our products, we will collect from you:
- Marketing and Communications including your preferences in receiving marketing from us and your communication preferences.
We will not share or sell your details with any third-party marketing organisations without your prior permission.
We may also collect and use Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, such as age eligibility to purchase alcohol, and you fail to provide that information as requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel the contract to supply these goods, but we will notify you if this is the case at the time.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you;
- create an account on our website
- subscribe to our webshop
- request marketing material to be sent to you
- enter a competition, promotion or survey
- give us some feedback.
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy [https://www.seggiano.com/cookies] for further details.
- Third parties or publicly available sources. We may receive anonymous personal data about you from various third parties as set out below;
- Technical Data from the following parties: analytics providers such as Google based outside the UK; search information providers based outside the UK.
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract, we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
We do not rely on consent as a legal basis for processing your personal data except when asking your consent to use cookies to customise your web experience and unless you consent to receive offers and news about our products. You have the right to withdraw consent to our communication at any time by contacting us or by selecting the unsubscribe button on any email you receive from us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To register you as a new customer |
|
Performance of a contract with you |
To process and deliver your order including:
|
|
|
To manage our relationship with you which will include:
|
|
|
| To enable you to partake in a prize draw, competition or complete a survey |
|
|
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
|
|
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
|
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences |
|
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you |
|
Necessary for our legitimate interests (to develop our products/services and grow our business) |
Marketing
We strive to provide you with choices regarding your personal data use, particularly around marketing and advertising. We have established the following personal data control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will only receive marketing communications from us if you have requested information from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
Third-party marketing
We will not share or sell your details with any third-party marketing organisations without your prior permission.
Withdrawal of consent
You can ask us to stop sending you marketing messages by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us directly or unsubscribing at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase, or other transactions.
Cookies
You can set your browser to refuse the use of browser cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or may not function properly. For more information about the cookies we use, please see https://www.seggiano.com/cookies
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
We will not use your personal data for an unrelated purpose.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
-
DISCLOSURE OF YOUR PERSONAL DATA
We may process your personal data with the parties set out below and solely for the purposes set out in the table in paragraph 4 above.
- Internal Third Parties as set out in the [Glossary].
- External Third Parties as set out in the [Glossary].
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
INTERNATIONAL TRANSFERS
Many of our external third parties are based outside the UK, so their processing of your personal data will involve a transfer of data outside the UK. For example, we may process your data using Netsuite Oracle
software based in the USA. We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called “binding corporate rules”. For further details, see European Commission: Binding corporate rules.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
Oracle has an Incident Response Policy and will escalate and notify customers of Security Breaches according to the procedures specified in the Oracle DPA for Cloud Services: http://www.oracle.com/us/corporate/contracts/cloud-services/index.html
DATA RETENTION
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Request erasure in the Glossary below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Request access to your personal data
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection- regulation-gdpr/individual-rights/right-of-access/
- Request correction of your personal data
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection- regulation-gdpr/individual-rights/right-to-rectification/
- Request erasure of your personal data
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection- regulation-gdpr/individual-rights/right-to-erasure/
- Object to processing of your personal data
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection- regulation-gdpr/individual-rights/right-to-object/
- Request restriction of processing your personal data
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection- regulation-gdpr/individual-rights/right-to-restrict-processing/
- Request transfer of your personal data
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection- regulation-gdpr/individual-rights/right-to-data-portability/
- Right to withdraw consent
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection- regulation-gdpr/individual-rights/rights-related-to-automated-decision- making-including-profiling/
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Any changes we make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Privacy Policy.
Contact
Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to [email protected]
GLOSSARY
Lawful basis
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Third parties
Internal Third Parties
Other companies in the Peregrine Trading Limited group. External Third Parties
- Service providers who provide IT, communication and system administration services, including, Oracle, Stripe, Paypal and Google (see below).
- Professional advisers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom, who require reporting of processing activities in certain circumstances.
- Other third parties such as courier companies used to deliver our goods.
We may disclose your personal data to the following, specific, external third parties:
| Oracle Corporation | a Netsuite cloud accounting provider, responsible for cookies. Please see their Privacy Policy at – www.oracle.com/legal/privacy/index.html |
| Stripe | Payments are handled through Stripe. Please see their Privacy Policy at – stripe.com/privacy |
| Paypal | Online payments system provider. Please see their Privacy Policy at – www.paypal.com/en/webapps/mpp/ua/privacy- full |
| Windcave | Merchant services payment conveyance. Privacy Policy at https://sec.windcave.com/pxmi3/privacy-policy |
| Gmail | Email provider. Please see their Privacy Policy at – policies.google.com/privacy |
| Devgroop | Website development, maintenance and technician services. Please see their Privacy Policy at Devgroop Privacy Policy |
| Mailchimp | Website development, maintenance and technician services. Please see their Privacy Policy at Mailchimp Privacy & Security |
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Organisations should refer to the ICO’s guide to the GDPR and privacy notices code of practice which provide detailed guidance.
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection- regulation-gdpr/individual-rights/