Ondg Ltd (“we”, “our”, “us” or “Ondg”) is committed to protecting the privacy of all users of our website www.ondg.co.uk, or mobile applications (together, the “Sites”). Please read the following privacy policy that explains how we use and protect your information. We are the “data controller” of the information we process, unless otherwise stated.

1. Contact Details
   

   If you have any queries or requests concerning this privacy policy or how we handle your data more generally, please get in touch with us using the following details. By contacting our general customer services team at: support@ondg.co.uk.
   
   

2. How We Collect Your Information
   

   We collect your personal information when you interact with us or use our services, such as when you use our Sites to place an order. We also look at how visitors use our Sites, to help us improve our services and optimise customer experience. We collect information: when you create an account with us or you change your account settings; when you place an order with us and during the order process (including for payment and order delivery); when you give us your consent to contact you via email, phone, post, message or via our chat function to send you marketing campaigns, or to invite you to participate in surveys about our services, or our partners services; when you participate in a competition, prize draw or promotion when you contact us directly via email, phone, post, message or via our chat function; and when you browse and use our Sites (before and after you create an account with us). We also collect information from third party sites, such as analytic providers, advertising platforms and our fraud detection provider.
   
   

3. Information We Collect From You
   

   As part of our commitment to the privacy of our customers and visitors to our Sites more generally, we want to be clear about the sorts of information we will collect from you. When you visit the Sites or make an Ondg order through the Sites, you are asked to provide information about yourself including your name, contact details, delivery address, order details and payment information such as credit or debit card information. We also collect information about your usage of the Sites and information about you from any messages you post to the Sites or when you contact us or provide us with feedback, including via email, letter, phone or chat function. If you contact us by phone, we record the call for training and service improvement purposes, and make notes in relation to your call. We collect technical information from your mobile device or computer, such as its operating system, the device and connection type and the IP address from which you are accessing our Sites. We collect survey response data based on the responses you choose to provide to any survey. We also collect technical information about your use of our services through a mobile device, for example, location data, unless you have elected to remain anonymous through your device and/or platform settings, this information may be collected and used by us automatically if you use the service through your mobile device(s) via any Ondg mobile application, through your mobile browser or otherwise. We process health information about you only where you volunteer and consent to this, for example if you specify any food allergies.
   
   

4. Use of your information
   

   We will only process the data we collect about you if there is a reason for doing so, and if that reason is permitted under data protection law. We will have a lawful basis for processing your information: if we need to process your information in order to provide you with the service you have requested or to enter into a contract; we have your consent; we have a justifiable reason for processing your data; or we are under a legal obligation to do so. Where we need to in order to provide you with the service you have requested or to enter into a contract, we use your information: to enable us to provide you with access to the relevant parts of the Sites; to supply the services you have requested; to enable us to collect payment from you; and to contact you where necessary concerning our services, such as to resolve issues you may have with your order. We also process your data where we have a justifiable reason for doing so for example personalisation of our service, including processing data to make it easier and faster for you to place orders. We have listed these reasons below: to improve the effectiveness and quality of service that our customers can expect from us in the future; to tailor content that we or advertising partners display to you, for example so that we can show you products which are in your area or make sure you see the advertising which is most relevant to you, based on characteristics determined by us; to enable our customer support team to help you with any enquiries or complaints in the most efficient way possible and to provide a positive customer experience; to contact you for your views and feedback on our services and to notify you if there are any important changes or developments to the Sites or our services, including letting you know that our services are operating in a new area, where you have asked us to do so; to send you information by post about our products, services and promotions (if you do not want to receive these, you can let us know by getting in touch (see Contact Details)); to analyse your activity on the Sites so that we can administer, support, improve and develop our business and for statistical and analytical purposes and to help us to prevent fraud; to enforce our contractual terms with you and any other agreement, and for the exercise or defence of legal claims and to protect the rights of Ondg, couriers, or others (including to prevent fraud); if you submit comments and feedback regarding the Sites and the services, we may use such comments and feedback on the Sites and in any marketing or advertising materials. We will only identify you for this purpose by your first name and the city in which you live; and where you have chosen to receive push notifications from us through our mobile application, we may send you push notifications relating to the services that you have requested from us and information about our services and offers. You can choose to stop receiving push notifications from us at any time by changing your preferences on your mobile device or by getting in touch (see Contact Details). We will also analyse data about your use of our services from your location data to create profiles relating to you and for you. This means that we may make certain assumptions about what you may be interested in and use this, for example, to send you more tailored marketing communications, to let you know about special offers or products which we think you may be interested in. This activity is referred to as profiling. You have certain rights in relation to this type of processing. Please see Your Rights section below for more information.
   
   

5. 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 Site may become inaccessible or not function properly. Please refer to our cookies policy for more details.
   
   

6. Direct Marketing
   

   If you have given consent to marketing we may contact you about our other products and services that may be of interest to you by email or phone. If you wish to opt out of direct marketing, please email support@ondg.co.uk. Where you have opted out of receiving marketing messages, this will not apply to personal data provided to us in connection with your purchase of a product or service or your involvement in other related transactions. If you have given consent, we may share your information with carefully selected third party organisations and business partners and they may contact you directly. If you would prefer to no longer receive direct marketing communications from third parties and partners after previously giving your consent, please contact those third parties and partners directly to withdraw your consent.
   
   

7. Fraud Prevention
   

   We will share your information with third party service providers such as our payment provider Stripe who conducts fraud checks on all customers. Such third parties will only have access to your information to the extent that they need to perform their services and they are required to keep your information confidential and may not use it other than as we ask them to and always in accordance with this Policy. Where we believe we may detect fraudulent activity we may block you from placing an order and using our Sites. We undertake fraud checks on all customers because this is necessary for us to perform our contracted services to customers, by ensuring that the services we provide are duly paid for, and also so that individuals themselves are protected from fraudulent transactions on their cards.
   
   

8. Retention of Your Information
   

   We will not retain your information for any longer than we think is necessary. Information that we collect will be retained for as long as needed to fulfil the purposes outlined in the Use of my information section above, in line with our legitimate interest or for a period specifically required by applicable regulations or laws, such as retaining the information for regulatory reporting purposes. When determining the relevant retention periods, we will take into account factors including: · our contractual obligations and rights in relation to the information involved; · legal obligation(s) under applicable law to retain data for a certain period of time; · statute of limitations under applicable law(s); · our legitimate interests where we have carried out balancing tests (see section on How we use your personal information above); · (potential) disputes; and · guidelines issued by relevant data protection authorities. Otherwise, we securely erase your information where we no longer require your information for the purposes collected.
   
   

9. Disclosure of your Information
   

   The information we collect about you will be transferred to and stored on our servers located within the EU. We are very careful and transparent about who else your information is shared with. Sharing your information internally: We share your information with other Ondg group companies only where necessary for the purposes set out in section 4. Sharing your information with third parties: If you consent to us sharing your information, or if we have a contractual right or other legal reason for sharing your information, we may share your information with third party service providers. The types of third party service providers with whom we may share your information includes: · Payment providers (including online payment providers and fraud detection providers): for the purposes of providing services to us, for example when they process information such as credit card payments for us, provide support services to you or carry out fraud checks for us; · IT service providers (including cloud providers): for the purposes of data storage and analysis; · Couriers: so they can deliver your order to you; · Customer support partners: who will help us to resolve any issues you may have with our services; and · Marketing and advertising partners: so that they can ensure that you see advertising which is more relevant to you and send you email and postal marketing on our behalf. Ondg will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy when it is transferred to third parties. If our business enters into a joint venture with, purchases or is sold to or merged with another business entity, your information may be disclosed or transferred to the target company, our new business partners or owners or their advisors. We may also share your information: · if we are under a duty to disclose or share your information in order to comply with (and/or where we believe we are under a duty to comply with) any legal obligation or regulatory requirement. This includes exchanging information with other companies and other organisations for the purposes of fraud protection and prevention; · in order to enforce our contractual terms with you and any other agreement; · to protect the rights of Ondg, or others, including to prevent fraud; and · with such third parties as we reasonably consider necessary in order to prevent crime, e.g. the police. International transfers of data: Whenever we transfer your information outside of the UK, we will take all reasonably practicable measures to protect your information in accordance with this policy and applicable laws. To the extent that any transfer requires approved safeguards to be in place we will only transfer your information to countries that have been deemed to provide an adequate level of protection for personal data. Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. Please contact us if you want further information on the specific mechanism(s) used by us when transferring your personal data out of the UK.
   
   

10. Security
    

    We adopt robust technologies and policies to ensure the personal information we hold about you is suitably protected. We take steps to protect your information from unauthorised access and against unlawful processing, accidental loss, destruction and damage. Where you have chosen a password that allows you to access certain parts of the Sites, you are responsible for keeping this password confidential. We advise you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will take steps to protect your information, we cannot guarantee the security of your data transmitted to the Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
    
    

11. Your rights
    

    Subject to applicable law, you may have a number of rights concerning the data we hold about you. If you wish to exercise any of these rights, please contact our Data Protection Officer by emailing support@ondg.co.uk. For additional information on your rights please contact your data protection authority and see below. To the extent provided by the law of your jurisdiction, you may request access to the personal information we maintain about you or request that we correct, update, amend, or delete your information, or that we restrict the processing of such information by contacting us as indicated below. You may have the right to obtain your personal information in an accessible and transferable format so that you can re-use it for your own purposes across different service providers. Where provided by law, you may withdraw any consent you previously provided to us or object at any time on legitimate grounds to the processing of your personal information, and we will apply your preferences going forward. This will not affect the lawfulness of our use of your information based on your consent before its withdrawal. You can object by changing your marketing preferences, disabling cookies as set out in sections 7 and 8 above or by getting in touch at support@ondg.co.uk.
    
    

12. Changes to our Privacy Policy
    

    Any changes to our privacy policy will be posted to the Sites and, where appropriate, we may notify you of the changes for example by email or push notification. This privacy policy was last updated: 01/02/2023.
    
    

13. Complaints
    

    If you are not satisfied with our response to any complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the Information Commissioner’s Office (ICO) using the following details: Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF Telephone number: 0303 123 1113 Website: www.ico.org.uk Ondg Ltd, 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom