Privacy Policy

Last updated: [Date]

This policy explains what personal information we collect when you use our website or become a customer, why we collect it, what we do with it, and the rights you have over it. We have tried to write it in plain English rather than legal boilerplate.

1. Who we are

We are [Company name], a company registered in England and Wales under company number [Company number], with its registered office at [Registered address].

For the purposes of UK data protection law we are the data controller for the information described in this policy. We are registered with the Information Commissioner's Office under registration number [ICO registration number].

If you have any question about this policy or about how we handle your information, contact [Data protection contact] at [Email address] or write to us at the address above.

2. The information we collect

Information you give us

• Enquiry and booking details. Your name, email address, telephone number, the location of your project, and anything else you choose to tell us when you contact us or book a consultation.
• Estimator responses. If you use the estimator on our website, the choices you make about size, finish, worktop, lighting and accessories, together with the contact details you give us if you ask for the summary by email.
• Newsletter sign up. Your email address.
• Customer and project information. If you become a customer, your delivery and installation address, site access details, survey measurements, photographs of your property taken for design and installation purposes, and your correspondence with us.
• Payment information. Records of the payments you make. Card details are handled by our payment provider and are not stored by us.

Information we collect automatically

• Technical data. Your IP address, browser type and version, device type, operating system and time zone setting.
• Usage data. Which pages you visited, how long you spent, what you clicked, and the website or advertisement that brought you to us.

Some of this is collected through cookies and similar technologies. See section 7.

Information from other sources

We may receive your details from a third party where you have asked them to introduce you to us, for example an architect, interior designer or builder working on your project. We may also receive information from social media platforms if you contact us through them.

3. Why we use your information, and our lawful basis

• Replying to your enquiry and arranging a consultation. We use your contact details and the content of your enquiry. Our basis is that these are steps taken at your request before entering into a contract.
• Producing an estimate or quotation. We use your estimator responses, contact details and project details. Our basis is that these are steps taken at your request before entering into a contract.
• Designing, manufacturing, delivering and installing your kitchen. We use your customer and project information. Our basis is performance of our contract with you.
• Taking payment and keeping accounting records. We use your payment records and contact details. Our basis is performance of our contract with you, and compliance with our legal obligations.
• Honouring our guarantee and handling aftercare. We use your customer and project information. Our basis is performance of our contract with you, and our legitimate interest in supporting the goods we supply.
• Sending our newsletter. We use your email address. Our basis is your consent.
• Following up on an enquiry you did not complete. We use your contact details and the content of your enquiry. Our basis is our legitimate interest in pursuing genuine enquiries, balanced against your interests.
• Improving our website and understanding how it is used. We use technical and usage data. Our basis is your consent for non essential cookies, and otherwise our legitimate interest in running the site well.
• Photographing completed projects for our portfolio. We use photographs of the installed kitchen. Our basis is your separate written consent, obtained before any photography takes place.

Where we rely on legitimate interests, we have considered whether our interest is overridden by your rights, and we have concluded it is not. You have the right to object, and section 8 explains how.

4. Photography of completed projects

We would often like to photograph the kitchens we build. We will always ask you first and will not photograph your home without your written agreement. You can say no, and it will make no difference to the service you receive. If you agree and later change your mind, tell us and we will stop using the images going forward, although we cannot recall printed material already distributed.

5. Who we share your information with

We do not sell your personal information. We share it only with the following:

• Our manufacturing workshop in Porto, Portugal, which receives the technical drawings and specification needed to build your kitchen, together with your project reference and the delivery address.
• Our installation team and delivery carriers, who receive your name, address, contact number and access details.
• Suppliers of worktops, appliances and other items where they need to deliver or template at your property.
• Service providers who help us run the business, including our website host, email and customer relationship platforms, accounting software, and payment provider. They act on our instructions and may only use your information for the purpose we specify.
• Professional advisers such as our accountants, insurers and solicitors.
• Authorities and regulators where we are required to do so by law.

6. Sending information outside the United Kingdom

Our workshop is in Portugal, which is in the European Economic Area. The UK Government has decided that the EEA provides an adequate level of protection for personal information, so your information can be transferred there without additional safeguards.

Some of our service providers are based outside the UK and the EEA, for example in the United States. Where that is the case we ensure an appropriate safeguard is in place, normally the UK International Data Transfer Agreement or the International Data Transfer Addendum to the EU Standard Contractual Clauses. You can ask us for details of the safeguards that apply.

7. Cookies

Cookies are small files placed on your device. We use them to make the website work, to remember your preferences, and to understand how the site is being used.

• Strictly necessary cookies. These make the website work, remember your progress through a form, and keep the site secure. We do not need your consent for these, because the site cannot function without them.
• Analytics cookies. These tell us which pages are visited and how people move through the site, so that we can improve it. We only set these with your consent.
• Marketing cookies. These measure whether an advertisement led to an enquiry, and allow relevant advertising to be shown to you. We only set these with your consent.

You can accept or reject non essential cookies using the banner shown when you first visit, and you can change your choice at any time using [Cookie settings link]. You can also block or delete cookies through your browser settings, although parts of the site may not work properly if you do.

Note for review: this section should list the actual cookies set once analytics and any advertising pixels are installed, including names, providers and durations.

8. Marketing

We will only send you our newsletter if you have asked for it, or if you are an existing customer and the content is about similar goods and services. Every email includes an unsubscribe link, and we act on unsubscribes promptly. Unsubscribing from marketing does not stop us sending you messages about a project we are carrying out for you.

9. How long we keep your information

• Enquiries that do not become projects. Kept for [24] months from your last contact with us.
• Estimator responses without contact details. Kept for [12] months, and held in anonymised form after that.
• Newsletter subscriptions. Kept until you unsubscribe, after which we keep a suppression record so that we do not contact you again.
• Customer and project records. Kept for the life of the guarantee, currently [25] years, so that we are able to honour it.
• Accounting and tax records. Kept for six years from the end of the relevant financial year, as required by law.

When we no longer need information we delete it securely, or anonymise it so it can no longer be linked to you.

10. Your rights

Under UK data protection law you have the right to:

• Be told how we use your information, which is what this policy is for.
• Access a copy of the information we hold about you.
• Correct information that is inaccurate or incomplete.
• Erase your information where there is no good reason for us to continue holding it.
• Object to our using your information where we rely on legitimate interests, and to object to direct marketing at any time.
• Restrict how we use your information while a question about it is resolved.
• Portability, meaning you can ask us to transfer information you gave us to you or to another provider in a machine readable format.
• Withdraw consent at any time where we rely on it.

To exercise any of these, email us at [Email address]. We will respond within one month. There is no fee, although we may charge a reasonable fee or refuse a request that is clearly unfounded or excessive. We may need to confirm your identity first.

11. Keeping your information secure

We use appropriate technical and organisational measures to protect your information, including access controls, encryption in transit, and limiting access to those who need it. We have procedures for dealing with a suspected data breach and will notify you and the Information Commissioner's Office where we are legally required to do so.

12. Children

Our website and services are intended for adults. We do not knowingly collect information about children. If you believe we hold information about a child, tell us and we will delete it.

13. Other websites

Our website may link to other sites, for example our social media profiles or a supplier's site. This policy does not apply to them, and we are not responsible for how they handle your information. Please read their own policies.

14. Changes to this policy

We may update this policy from time to time. The date at the top shows when it was last changed. If we make a significant change we will tell you, for example by email or by a notice on the website.

15. Complaints

If you are unhappy with how we have handled your information, please tell us first so that we can put it right. You also have the right to complain to the Information Commissioner's Office, the UK supervisory authority for data protection.

Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. Telephone 0303 123 1113. Website ico.org.uk.