PRIVACY AND COOKIES POLICY

PRIVACY AND COOKIES POLICY

Mastra Ma’ Ltd 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.mastrama.com (“Our Site”) 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 and Cookies Policy carefully and ensure that You understand it. Your acceptance of the Cookies part of this Privacy and Cookies Policy will occur when You tick the consent box on Our Site and You acceptance of the privacy part of this Privacy and Cookies Policy is deemed to occur upon Your first use of Our Site, when signing up for an Account or checking out as a guest (where no Account is required). If You do not accept and agree with this Privacy and Cookies Policy, You must stop using Our Site immediately.

1. DEFINITIONS AND INTERPRETATIONS

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 certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by 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 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011.

2. INFORMATION ABOUT US

Our Site is owned and operated by Mastra Ma’ Ltd a Limited company registered in England and Wales under company number 11245831.

Registered address: C/O Maygrove Rd, West hampstead, NW6 2EG, London, United Kingdom

VAT number: 289936329

Data Protection Officer and Representative: Emanuela Loppo.

Email: data-protection@mastrama.com

Postal address: C/O Maygrove Rd, West hampstead, NW6 2EG, London, United Kingdom

3. WHAT DOES THIS POLICY COVER?

This Privacy and  Cookies 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 and Cookies 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 ICO has more guidance on their website, [here]
• The right to access the personal data we hold about You. Part 13 will tell You how to do this. The ICO has more guidance on their website, [here]
• 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 ICO has more guidance on their website, [here]
• 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 ICO has more guidance on their website, [here]
• The right to restrict (i.e. prevent) the processing of Your personal data. Please contact Us using the details in Part 15 to find out more. The ICO has more guidance on their website, [here]
• The right to object to Us using Your personal data for a particular purpose or purposes. Please contact Us using the details in Part 15 to find out more. The ICO has more guidance on their website, [here]
• 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. Please contact Us using the details in Part 15 to find out more.
• 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. Please contact Us using the details in Part 15 to find out more.
• Rights relating to automated decision-making and profiling. We do not use Your personal data in this way.

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. We do not collect any ‘special category’ or ‘sensitive’ personal data or personal data relating to children but please refer to Part 16 on this.

7. HOW DO YOU USE MY PERSONAL DATA?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data which comprises consent, contract, legal obligation and legitimate interests. More details on each lawful basis and examples of how we use Your personal data under each basis are as follows:

Consent

Where You have expressly provided Your consent to receive communications from Us such as newsletters, emails, marketing materials, news and events, new products and exclusive sales and curated marketing events. Consenting to the use of cookies on Our site is used to make Your experience on Our site more seamless by, for example but not limited to, remembering pages You have previously visited, products You have clicked on, automatically generated forms.

Contract

Your personal data is necessary for Us to administer the pre-purchase, purchase and contractual relationship with You so that we may communicate with You about orders, returns, after sales service, set up and manage accounts, complete purchases or payments, store and record Your purchases and previous orders, fulfil orders received via social media campaigns, ship and dispatch purchases made via Our Site and keeping You updated with any changes in our terms and policies as well as offering You additional products, services and benefits as a valued customer of Ours.

Legitimate Interest

Where You have provided Your email address or other personal data to Us, either online or offline, we may add You to Our database for emails to contact You about new products, news and events, exclusive sales and curated marketing events. If we notice an abandoned cart on Our Site, whether You have set up an Account or not, we may use Your personal data provided to contact You about the abandoned cart. Certain personal data is also needed for legitimate purposes to prevent fraud, security breaches, legal violations, for Us to help recommend products to You and to understand more about Our customer and targeted customer base as well as to help the Site to switch to the correct currency, language and delivery options if applicable. We may also use the personal data collected under this lawful basis to help Us analyse and administer, improve and update Our Site for better experience, better products and service we offer.

Legal Obligation

Certain personal data You provide Us is necessary for Us to fulfil Our legal obligations as a business for example, verifying Your age and appropriate use of Our Site, preventing fraud, security breaches and complying with Our tax and accounting obligations where needed.

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. See Part 11 for more details.

Third Parties whose content appears on Our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise You to check the privacy policies of any such third parties.

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 MY YOU KEEP YOUR 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. Even if we delete Your personal data, it may still exist on backup or archival media for legal, tax or regulatory purposes.

9. HOW AND WHERE DO YOU STORE OR TRANSFER MY PERSONAL DATA?

We will store or transfer some of 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.

We may store or transfer some or all of Your personal data in countries that are not part of the EEA. These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional 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 follows:

We use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts require the same levels of personal data protection that would apply under the Data Protection Legislation. More information is available from the European Commission.

Please contact Us using the details below in Part 15 for further information about the particular data protection mechanisms used by Us when transferring Your personal data to a third country. The security of Your personal data is essential to Us and to protect Your data, we take a number of important technical and organisational 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 and aware of any obligations relating to the use of Your personal data by them; and
• 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.

10. DO YOU SHARE MY PERSONAL DATA?

Subject to part 9, We will not share any of Your personal data with any third parties for any purposes, subject to the following exception[s].

If we sell, transfer, or merge parts of Our business or assets, Your personal data may be transferred to a third party. 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 may share Your personal data with Our employees, agents, professional advisers to ensure collect filing and logistics of orders, dispatches, deliveries and invoicing. We may also need to share Your personal data to relevant authorities for example to facilitate the detection of crime or collection of taxes or duties.

We may sometimes contract with the following third parties to supply certain services.

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.

11. HOW CAN I CONTROL MY PERSONAL DATA?

In addition to Your rights under the Data Protection Legislation, set out in Part 5, when You submit personal data via Our Site, 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).

If You are based in the United Kingdom, 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.

12. CAN I WITHHOLD INFORMATION?

You may access certain areas of 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.

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.

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 14 calendar days 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. Some Third-party Cookies are used on Our Site for essential analytics and SEO such as Google Analytics and Google Tag Manager. We have carefully set up the use of these cookies to only allow collection of data which is essential for the correct functioning of our website.

In particular, we track website traffic to understand how visitors use our website. This traffic data is anonymized and does not include your IP address. It may include information like the number of visitors, pages viewed, city-level location, device used and referring links. Tracking this data is essential to ensure the website functions properly and provides the best possible user experience. We use this data to identify areas for improvement, such as optimizing website performance and content delivery.

We use Google Analytics 4 (GA4) for this purpose. We set it up to specifically only collect essential website traffic data. In particular, in our set up we do not allow the following:

We disabled the Google signals data collection. When Google signals is turned off, Google Analytics will not collect visitation information (such as end-user detailed location, search history, YouTube history and data from sites that partner with Google) and associate it with Google’s information from accounts of signed-in users who have consented to this association for the purpose of ads personalisation.

We disabled the user ID and user-provided data collection. With this feature turned off we will not connect visitors’ behaviour across different sessions and the various devices and platforms from which they visit. Google Analytics interprets each distinct user ID as a separate user, which provides the brand with more accurate user counts and a more holistic story about a user’s interactions with your business.

We disabled the advanced settings to allow for ads personalisation. When ads personalisation is not allowed, we may not export the Google Analytics audiences and key events to our linked Ads accounts for the purpose of delivering relevant, personalised experiences to end users.

While we have configured Google Analytics 4 for privacy-focused data collection, you can still opt-out of Google Analytics tracking entirely by installing the Google Analytics opt-out browser add-on.

In alternative, you can typically disable cookies through your browser settings. To learn more about how to manage cookies, please visit this general resource about disabling cookies.

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 screen 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 may block these Cookies by changing Your internet browser’s settings. For further details, please consult the help menu in Your internet browser or the documentation that came with Your device.

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.

Our Site may use analytics services from time to time. 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.

You may contact Us for more details on strictly necessary and third party Cookies we use.

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:

Email: data-protection@mastrama.com.

Postal Address: C/O 75 Maygrove Rd, West Hampstead, London NW6 2EG, UK.

16. GENERAL

You may not transfer any of Your rights under this Privacy and Cookies Policy to any other person. Subject to Our Site Terms and Conditions, anyone under the age of 18 should not use Our Site but in the event someone under the age of 18 uses Our Site and accepts this Privacy and Cookies Policy without parental responsibility consent or on another unauthorised basis, We shall not be liable for any breach of the Data Protection Legislation relating to the personal data We collect as a result of such use. We may transfer Our rights under this Privacy and Cookies Policy where we reasonably believe Your rights will not be affected.

If any court or competent authority finds that any provision of this Privacy and Cookies Policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Privacy and Cookies Policy will not be affected.

Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

This Privacy and Cookies Policy will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

17. CHANGES TO THIS PRIVACY AND COOKIES POLICY

We may change this Privacy and Cookies Policy  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 and Cookies 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 and Cookies Policy was last updated on the 30th of October 2019.

18. COOKIES BANNER

Text as follows: Certain features of our site depend on primary cookies to function. Cookie Law deems these cookies to be strictly necessary for the use of the site as intended. Other third party cookies are used to personalise content and ads, to provide social media features and to analyse our traffic. Whilst third party cookies are not integral to the functioning of our site, their use is recommended to allow us to provide and improve our products and services to you. By clicking ‘Accept’, you consent to the use of all cookies. If you wish to limit use of some cookies you may do so through the relevant section of your browser. You can find additional details in our Privacy and Cookies Policy.

19. PAYPAL SELLER PROTECTION DISCLAIMER

Our transactions are covered by PayPal Seller Protection.