We, Pick Your Own Limited (trading as PICK.YOUR.OWN.), a company registered in England and Wales with company number 15551422 and registered office at Holbrooks Farm Benington Road, Aston, Stevenage, England, SG2 7EA (“we”, “us”, or “our”) respect your privacy and are committed to protecting your personal data.

This privacy policy (our “Policy”) aims to inform you on how we look after your personal data when you use our website: https://pyopickyourown.com/ (“Website”) and our app: PICK.YOUR.OWN. (“App”) (in either case, our “Platform”). The Policy also tells you about your privacy rights and how the law protects you and your personal data.

If you have any questions about this Policy, please contact us on the contact details set out in Section 1 ‘About Us’.

The Platform is not intended for children, and we do not knowingly collect data relating to children.

Pick Your Own Limited is the controller and responsible for your personal data.

If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:

Full name of legal entity: Pick Your Own Limited

Email address: info@pyopickyourown.com

Postal address: 70 Mark Lane, Fenchurch Street, EC3R 7HS

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator 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.

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, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data	Includes first name, last name and individual username or similar identifier.
Account Data	Includes your password, username and your preferences, feedback and survey responses.
Contact Data	Includes your home address, work address, billing address, email address and telephone numbers.
Financial Data	Includes bank account and payment card details and details relating to fees charged to or paid by you.
Technical Data	Includes internet protocol address, login data, browser type and version, time zone setting, browser plug-in types and versions, and operating system and other technology you use to access our Platform.
Usage Data	Includes information about how and when you use our services and the Platform.
Marketing and Communications Data	Includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Location Data	Includes your device and/or browser location, your location, and any additional location data stored within your Google account if you link this to the Platform.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Platform 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 Policy.

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 our relationship with you.

We use different methods to collect data from and about you including through:

Direct Interactions	You may give us your personal data when you: Subscribe to use our services on the Platform; Make payments to us; Enquire about our services or otherwise correspond with us by post, phone, email, or otherwise; Give us feedback or respond to a survey or questionnaire.
Automated Technologies or Interactions	As you interact with the Platform, we will automatically collect Technical, Location, and Usage Data. We collect this personal data by using cookies and other similar technologies (see Section 7 'Cookies').
Third Parties or Publicly Available Sources	We will receive Technical Data about you from various third parties based both inside the UK and outside the UK, such as analytics providers like Google and social media platforms such as Facebook, Instagram, and Twitter.

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 access to the Platform). In this case, we may have to cancel a service or account you have with us, but we will notify you if this is the case at the time.

We will only use your personal data when the law allows us to and we are required by law to have a lawful basis for processing personal data. In particular, at least one of the following must apply whenever we process personal data:

Performance of Contract	We will process your personal data where we need to in order to perform the contract we are about to enter into or have entered into with you.
Legitimate Interests	We will process your personal data where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. “Legitimate Interest” means our interest in conducting and managing our business to enable us to give you the best service and the 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).
Legal Obligations	We will process your personal data where it is necessary for compliance with a legal obligation in the UK or EU that we are subject to.
Vital Interest	We will process your personal data where it is necessary to protect someone’s life.
Public Task	We will process your personal data where it is necessary to perform a task in the public interest and the task has a clear basis in law.
Consent	Generally, we will not rely on consent as a legal basis for processing your personal data, although we will get your consent before collecting or processing any special category data (for example, data relating to race, ethnicity, political, religious or philosophical beliefs, trade union membership, health data and/or sexual orientation). You have the right to withdraw consent at any time by contacting us.

Special Category Personal Data

We do not collect any “Special Category 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.

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 lawful 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 basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific lawful basis we are relying on to process your personal data.

Purpose/Activity	Type of Data	Lawful Basis for Processing
To register you as a new user/customer on the Platform.	(a) Identity (b) Contact (c) Account (d) Financial (e) Location	Performance of a contract with you
To deliver services to you on our Platform.	(a) Identity (b) Account (c) Contact (d) Financial (e) Usage (f) Communication	Performance of a contract with you
To deliver relevant Platform content to you and measure or understand the effectiveness of the content we provide to you.	(a) Identity (b) Contact (c) Account (d) Usage (e) Technical (f) Location	Necessary for our legitimate interests (to study how users use our services, to develop them, to grow our business and to inform our business strategy)
To process and manage orders, payments, fees and charges and collect or recover money owed to us using the Platform.	(a) Identity (b) Contact (c) Financial (d) Account (e) Location	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us and ensure the proper functioning of the Platform)
To manage our relationship with you on our Platform, which will include notifying you about changes to our Terms and Conditions or Privacy Policy.	(a) Identity (b) Contact (c) Account (d) Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how users use our services)
To administer and protect our business and our Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).	(a) Identity (b) Contact (c) Technical (d) Usage	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To use data analytics to improve our Platform, services, and user relationships and experiences.	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of users for our services, to keep our Platform updated and relevant, to develop our business and to inform our business strategy)

Please see our Cookie Policy below for further details on our use of cookies. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Platform may become inaccessible or not function properly.

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.

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. 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.

We may share your personal data with the parties set out below for the purposes explained in Sections 5 and 6 above:

• Third parties for the purpose of providing the services to you via the Platform. For example, payment processing providers.


• Our affiliates and/or companies within the group.


• 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.

Whenever we transfer your personal data out of the UK to countries which have laws that do not provide the same level of data protection as the UK law, we always ensure that a similar degree of protection is afforded to it by ensuring that our arrangements have a legal basis or, if necessary, an appropriate safeguard is in place to protect your personal data during and after the transfer.

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.

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.

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. Please note that 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.

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.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us. In some circumstances you can ask us to delete your data: see Section 13 ‘Your Legal Rights’ below for further information.

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.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. We have summarised these below. For more information, please see the ICO website here: https://ico.org.uk/your-data-matters/.

• 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 your personal data. 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. You can 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 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 transfer of your personal data. 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.


• Right to withdraw consent. You can 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 services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us. We try to respond to all legitimate requests within one month. Occasionally it could 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.

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.

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.

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. This cookie policy (“Cookie Policy”) sets out the types of cookies we use, the purpose of using them, the duration of each cookie, and any third parties that may also use cookies.

This Cookie Policy should be read together with our Privacy Policy [see above] and sets out how and why we collect, store, use and share personal information in relation to our platforms, as well as your rights in relation to your personal information and details of how to contact us and supervisory authorities if you have a complaint.

We are, Pick Your Own Limited (trading as PICK.YOUR.OWN) (also referred to as “we”, “our”, or “us”). We are registered in England and Wales under the company number 15551422 and having our registered office at Holbrooks Farm Benington Road, Aston, Stevenage, England, SG2 7EA.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive. For example, we may monitor how many times you visit the website, which pages you go to, traffic data, location data, and the originating domain name of your internet service provider. This information helps us to build a profile of our users. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually.

We will ask for your permission (consent) to place cookies or other similar technologies on your device, except where they are essential for us to provide you with a service that you have requested.

If you consent to the use of cookies on our website, this consent will last for the period noted in the table below. After the expiry of this period, we will seek your consent again for the use of cookies when you access the website again. If you do not select agree or disagree to our use of cookies or do not agree to the use of cookies, the cookie consent message will appear each time you access our website.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. These essential cookies are always enabled because our website won’t work properly without them. They include, for example, maintaining a user’s browsing activities in a single session. You can switch off these cookies in your browser settings but you may then not be able to access all or parts of our website.


• Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.


• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).


• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that the following third parties may also use cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third party cookies are likely to be analytical cookies or performance cookies or targeting cookies.

If you do not want to accept any cookies, you may be able to change your browser settings so that cookies (including those which are essential to the services requested) are not accepted. If you do this, please be aware that you may lose some or all of the functionality of our services.

For further information about cookies and how to disable them please go to the guidance on cookies published by www.aboutcookies.org or www.allaboutcookies.org.

We may change this Cookie Policy from time to time, when we do, we will inform users by posting an updated policy on the website.

If you have any questions or concerns about our use of cookies, please send us an email at info@pyopickyourown.com.