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PRIVACY STATEMENT
Effective date: February 2019

Tony’s Chocolonely Privacy Statement 
Tony’s Chocolonely works very hard every day to make the chocolate world 100% slave-free. That is why we tell you exactly where our chocolate comes from. We want to be just as clear about the personal data you provide us with. That is why we will explain this to you in this Privacy Statement. 

1. Who we are
We are Tony’s Chocolonely Ltd. Our registered address is 1st Floor Rosedale Studios, Rosedale Road,
Richmond, TW9 2SX, the United Kingdom. Our Company Number is 11565535. We can be reached by email at mailuk@tonyschocolonely.com or you can call our chocophone at + 31 20 - 20 512 00.

2. What do we use your personal data for? 
We have asked you to provide certain personal data, such as your name, email address, address and payment details including your bank account number and telephone number.

We use this personal data to process your order, to check the progress of your order and to send you an invoice. If you do not provide us with this personal data we will not be able to deliver the chocolate products you bought. We also use your personal data to communicate with you, for example, if we want to check certain aspects regarding the order and delivery with you. 

3. How we collect your personal data
We collect your personal data in different ways:

  • Direct interactions with you: for example when you write to us by post, phone, email or otherwise, sign up to our newsletter or create a Choco account.
  • Automated technologies or interactions: as you use our website, we will automatically collect data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
  • Third parties or publicly available sources: we will receive personal data about you from many third parties such as analytics providers (such as Google based outside the EU) or providers of technical, payment and delivery services (such as Adyen, which is based in the EU).

4. Choco account
It is convenient if you create an account yourself, because then you do not have to submit all your personal data for each new order. In your account you can view and update your personal data. Here you will also find information relating to orders placed, an overview of the invoices, returns, and information you wish to receive, such as newsletters. You can manage your account by logging in. 

5. Tony’s and its customers 
We would like to get to know you well to be able to accommodate you where possible. We will record your contact and purchasing details in our customer system. We will also record whether you have participated in our campaigns. Furthermore, we will keep track of our contact moments and of what we discussed during our contact with you. This way we will know which products you find interesting, how often you visit us and what keeps you busy. With this information, for example, we can inform you about the impact you had: how the position of the chocolate farmers has improved thanks to you. We also use this information to continuously improve and update our website and our product range, to develop campaigns and to keep you informed based on your interests. 

6. On what basis do we process your personal data?
According to the law, we have to let you know the ‘legal bases’ on which we process your personal data. These are the following: (i) your consent, for example if you have given your consent to receive the newsletter (ii) to perform a contract with you , for example when you place an order, (iii) on the basis of a legal obligation, for example based on tax legislation and (iv) if we have a legitimate interest in doing so, for example for maintaining contact and to keep track of your interests. 

7. Newsletter
We can also use your email address to send you a newsletter, containing information about our new products, promotions or other news. We will only do so if you have given us your consent. You can withdraw this consent using the ‘unsubscribe’ link you find at the bottom of each newsletter. By the way, this will always apply. If you have given us consent to use your personal data, you can always withdraw your consent just as easily.

8. Who else will receive your personal data? 
We care about your personal data and we will only share it with others if this is necessary to ensure that you will receive your order. We select authorised third parties and review their privacy and security policies. Examples are our payment processors, technology support, delivery services, the distribution centre and also the printing company if you ordered a personalised wrapper. We do not share your personal data with others for advertising purposes and if you surf the internet we will not show you advertisements from Tony's on other sites.

9. How long do we keep your personal data?
The statutory obligation to retain data in accounts receivable records and sales records is a seven-year period. This means that, in any case, we retain personal data such as your name, email address, address, payment details, telephone number and – for business customers - also data such as the Company Registration Number and the VAT number, for a period of seven years. 

10. How do we keep your personal data safe?
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 only give access to your personal data to 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 also have procedures in place to deal with any suspected personal data breach. If there is a breach, we will notify you and any applicable regulator where we are legally required to do so.

11. International
We just prefer to keep your personal data as close as possible, but we may need to share your data sometimes, for example with our US office. If it is necessary to share your personal data with parties outside the European Economic Area (EEA), we will only do so if a particular statutory exception applies or if so-called appropriate safeguards have been put in place. These appropriate safeguards will ensure that your personal data is used outside the EEA in accordance with European standards. For example:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data outside the EEA.

12. Questions about your personal data 
If your personal data is incorrect, you can always ask us to correct it. If you have created an account, you can often update your personal data yourself. If you wish to view your personal data or receive a copy, this is possible as well. Sometimes, it is also possible to have your personal data erased, to object against the use of your personal data or to limit its use. In certain cases it is even possible to request your personal data and to take it to another party. For all these questions please contact us at mailuk@tonyschocolonely.com or you can call our chocophone at + 31 20 - 20 512 00. 

13. Complaints?
If you have any complaints about how we handle your personal data, we do regret that. In this case, send an email to mailuk@tonyschocolonely.com, or call our chocophone (+31 20 - 20 512 00). We will be happy to help you find a solution. If a solution cannot be found, you can always contact the Information Commissioner’s Office (ICO) at https://ico.org.uk/

14. Changes
We continue to work on a better product and a better website. As a result, sometimes there are changes to the personal data we ask you for and what we do with this personal data. Regulations may also change. In this case, we will amend this Privacy Statement. Therefore, please check this Privacy Statement regularly so that you stay up to date. If there are major changes, we will inform you via our website.