Privacy Policy

Important information and who we are

Introduction

2. Welcome to the privacy policy of Togather. This website is operated by Karamu Limited, a company registered in England and Wales under Company Number 10186089, whose registered office is at 6 Orsman Road, London, N1 5RA.

Purpose of this privacy policy

2. This privacy policy sets out how Togather uses and protects any information that you give to us when you use this website.
3. We are committed to protecting your personal data, using it responsibly and ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy policy.
4. This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.
5. This website is not intended for children and we do not knowingly collect data relating to children.
6. It is important that you read this privacy policy together with any other privacy policy or fair processing policy 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 policy supplements other notices and privacy policies and is not intended to override them.
7. We may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes.

Data controller

8. Karamu Limited trading as Togather is the data controller and responsible for your personal data (collectively referred to as Togather “we”, “us” or “our” in this privacy policy).
9. We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the privacy manager using the details set out below.

Contact details

10. If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager:
    Full name of legal entity: Karamu Limited t/a Togather
    Email address: contact@togather.com
    Postal address: 6 Orsman Road, London, N1 5RA
    Telephone number: +44 (0) 203 905 7439
11. 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 policy and your duty to inform us of changes

12. We keep our privacy policy under regular review. This version was last updated on 5th June 2019. Historic versions can be obtained by contacting us.
13. 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

13. This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

The data we collect about you

2. 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).
3. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
1. Identity data: Your name and address, and the name and addresses of the organisation booking any services through the website (if different).
2. Contact Data: Your billing address, delivery address, email address and telephone number.
3. Transaction Data: Details about payments to and from you and other details of products and services you have purchased from us.
4. Profile Data: Your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
5. Usage Data: Information about how you use our website, products and services.
6. Marketing and Communications Data: Your preferences in receiving marketing from us and our third parties and your communication preferences.

1. 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

1. Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

How is you personal data collected?

2. 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:
     • apply for our products or services;
     • create an account on our website;
     • subscribe to our service or publications;
     • request marketing to be sent to you;
     • enter a competition, promotion or survey;
     • or give us feedback or contact us.
   • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
   • Third parties or publicly available sources.We will receive personal data about you from various third parties and public sources as set out below:
     • Technical Data from the following parties:
       • analytics providers such as Google and Mixpanel both based outside the EU;
       • advertising networks such as Google based outside the EU; and
       • social media platforms such as Facebook and communications/search networks such as Google/Gmail via which you may elect to login automatically to the Platform (who may be based outside the EU); and
       • search information providers such as Google based outside of the EU, and Bing based outside of the EU.
   • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as our payment process provider Stripe, who may be based outside the EU.
   • Identity and Contact Data from customer service tools such as Intercom, who may be based outside the EU.
   • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
   • Mailchimp is a tool for managing and sending newsletters – We may ask for and use Your Identity Data and Contact Data to link to a page hosted by Mailchimp. If You unsubscribe from our Mailchimp emails, you will be landed on a page hosted by Mailchimp.

How we use your personal data

1. We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:
   1. Our own internal record keeping.
   2. We will need to pass on certain information such as your name and email address to our Caterers in order that they can provide the services you wish to book.
   3. We may use your information for the purposes of providing you with our services and customer care.
   4. We may need to disclose your information to public authorities, if requested by them or required by law. Click here to find out more about the types of lawful basis that we will rely upon to process your personal data.
   5. We may use the information to improve our services.
   6. We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided. You may choose to unsubscribe from receiving this information at any time by following the instructions on the emails sent to you.
2. Generally, we do not rely on consent as a legal basis for processing your personal data although we will obtain your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purpose for which we will use your personal data

2. 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.
3. 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.

Marketing

5. We provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You should contact our data privacy manager if you want to know how we are using your personal data and if you withdraw consent for us to do so.

Financial Data

6. We do not store any personal credit or debit card details. Any debit or credit card transactions are carried out by reputable third parties (our payment process providers) and only they will hold your details.
7. We will store company account and financial details (name, account number, sort code, VAT number, company registration number) for members where required so that we can send funds to you without delay.
8. Where financial data is processed it is only done so for the purpose of processing your booking.

Promotional offers from us

9. 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 (we call this marketing).
10. You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have opted-in to receive that marketing.

Third-party marketing

11. We will obtain your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting-out

12. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you, or by contacting us at hello@togather.com.
13. 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 or service purchase or other transactions.

Cookies

14. A cookie is a small file which asks permission to be placed on your computer’s hard drive. The file is added, and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
15. We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
16. Cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website or making bookings.
17. If you would like to know more information on managing cookies in your browser including how to opt out of receiving cookies, please visit www.aboutcookies.org or www.allaboutcookies.org.

Change of purpose

18. 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 want us to explain as to how the processing for the new purpose is compatible with the original purpose, please contact us.
19. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
20. 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.

Disclosures of your personal data

1. We may share your personal data with the parties set out below for the purposes set out in the table “Purposes for which we will use your personal data” above.
   1. External Third Parties as set out in the Glossary.
   2. Specific third parties listed in the table “Purposes for which we will use your personal data” above.
   3. 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 policy.
2. 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

1. We do not transfer your personal data outside the European Economic Area (EEA).

Data security

1. We are committed to ensuring that your information is secure.
2. In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
3. 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.
4. 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.
5. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

How long will you use my personal data for?

1. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
2. 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, regulatory, tax, accounting or other requirements.
3. Details of retention periods for different aspects of your personal data are set out in the table “Purposes for which we will use your personal data” above.
4. 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.
5. In some circumstances you can ask us to delete your data: see "Your legal rights" below for further information.
6. In some circumstances we will 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

1. 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:
   1. Request access to your personal data
   2. Request correction of your personal data
   3. Request erasure of your personal data
   4. Object to processing of your personal data
   5. Request restriction of processing your personal data
   6. Request transfer of your personal data
   7. Right to withdraw consent
2. If you wish to exercise any of the rights set out above, please contact our data privacy manager and make a Subject Access Request.

No fee usually required

3. 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 could refuse to comply with your request in these circumstances.

What we may need from you

4. 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

5. We will 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.

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 obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third parties

External third parties

Service providers acting as processorsbased in the United, the EU, and USA who provide IT and system administration services.

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

Your legal rights

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: - If you want us to establish the data’s accuracy. - Where our use of the data is unlawful but you do not want us to erase it. - 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. - 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.