Date of last revision: 21 July 2021
Welcome to Tuck Trucks (the “Site”), owned by The Ho-So Initiative Ltd (“We” and related words such as “us” and “our” in this privacy notice)
Tuck Trucks takes your privacy seriously, and is committed to protecting and respecting it.
We want you to understand how we collect and use information about you.
The privacy notice describes who we are, what personal data we collect and store about you, and how we collect it, why we collect personal data and what we do with it, the categories of third parties with whom we share your personal data, how we retain your information and keep it secure, your rights and how to exercise them and how to contact us. It also contains information on the correct people to contact in the unlikely event that you have a complaint.
Who are we?
Our name: The Ho-So Initiative Limited
Place of incorporation: England and Wales (this is where we are registered)
Company number: 12465469
Registered address: Devonshire House, 1 Devonshire St, London, UK W1W 5DR
Under data protection law, we are considered to be a “controller”. As a controller, we are responsible for, and control the processing of, your personal data. We are registered as a data controller with the Information Commissioner’s Office, which is the UK’s supervisory authority for data protection matters.
What information do we collect from you?
In the course of our business – acting as a portal to connect customers with vendors selling food– we collect the following personal data:
– personal details, such as name and title, gender, date of birth
– contact data, such as physical address, e-mail address, telephone and mobile number(s)
– biographical and other data, such as institutions attended, qualifications gained, relevant experience, and any other personal information you provide
– payment details, such as bank account, card details
– transaction data, such as details about payments to and from you, details of services you have purchased from us
– technical data, such as internet protocol (IP) address, your login data, browser type and version, time-zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website
– profile data, such as username and password, viewing official bookings made by you, your preferences, feedback and survey responses
– usage data, such as information about how you use our website and services
– marketing data, such as your preferences in receiving marketing and communications.
We do not knowingly collect “special category” personal data. This is a special type of sensitive data to which more stringent processing conditions apply, and comprises data concerning your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation, and genetic data and/or biometric data.
We also do not collect information about criminal convictions or offences save where we are acting as an employer, in which case our internal privacy notice will apply and will be made available to those covered.
How do we collect personal data?
We obtain personal data from sources as follows:
– Directly from you when you interact with us, for example when you create or cancel an order, request a refund, request information, write to us, phone our customer services team (since your call may be recorded for training, fraud prevention and investigation purposes), enter a competition, take part in a survey, give us feedback or post comments or reviews, apply for a job or send a CV
– Others, if they provide your details (for example, if you are copied on an e-mail that is sent to us, and your e-mail address identifies you, we will have collected your personal data. If you are providing another person’s details, please ensure you have that person’s explicit consent to do so
– Reference sources, for example any other people / entities you authorise us to contact.
How do we use your personal data?
We will use your personal data only when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
– to allow you to place an order
– to perform a contract we are about to enter into, or have entered into, with you
– if it is necessary for our legitimate interests (or those of a third party) and these are not overridden by your own rights and interests
– where we need to comply with a legal or regulatory obligation.
In order to process personal data, we must have a lawful reason. We always ensure that this is the case, and we set out our lawful reasons below – but please note that more than one may apply at any given time: for example, if we inform you of changes to our privacy notice, we may process your personal data on the ground of complying with law and on the ground of legitimate interests.
We will use your personal data only for the purposes for which we collected it, unless we fairly consider that we need it for another reason that is compatible with the original purpose.
Please contact us if you would like more information on this, and on situations in which more than one lawful basis applies.
If you are a customer placing an order, or individual applying for a job, we will process your personal data for the following purposes, on the legal basis that it is necessary for us to provide our services to you:
– to identify you
– to respond to your enquiries
– to allow you to place an order
– to the extent necessary to provide information about a food vendor or order
– to provide our services
– to carry out billing and administration activities
– to evaluate your job application and take any next steps, and to evaluate your suitability for roles where you have asked to be considered for future opportunities.
We process your personal information for our legitimate business purposes, which include the following:
– to conduct and manage our business
– to enable us to carry out our services
– to help identify suspicious purchasing activity
– to ensure our website and systems are secure (for example, by conducting security penetration tests on our website to ensure our security tools are effective)
– to personalise your web experience – for example, by tailoring our offers to you
– to analyse, improve and update our services for the benefit of our customers
– to deal with complaints
– to let you know about our services, promotions or events that we consider may be of interest to you (and which may be tailored to your interests as construed from your purchase history): we carry out this processing on the legal basis that we have a legitimate interest in marketing our services, and only to the extent that we are permitted to do so by applicable direct marketing laws. Please see below for further information about our marketing activities and regarding your right to opt out.
Whenever we process your personal data for these purposes, we ensure that your interests, rights and freedoms are carefully considered.
Compliance with laws
We may process your personal data in order to comply with applicable laws (for example, if we are required to co-operate with an investigation pursuant to a court order).
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via e-mail or text message. You have the right to withdraw consent to marketing at any time. This will not affect the lawfulness of processing that took place prior to the withdrawal of consent.
We will always be clear whenever we intend to process on the basis of consent, and we will process lawfully and only for the purpose for which consent was given.
Do we share your personal data?
We may provide your personal data to the following recipients for the purposes set out in this notice:
– other companies in our group or under common ownership
– business partners from whom you have expressed a willingness to receive or consider receiving a service
– business partners with whom we have entered into, or are about to enter into, a commercial collaboration under which they provide services to us, in circumstances in which the sharing of your personal data is reasonably required for that collaboration and this requirement is not outweighed by your rights
– our service providers, including:
– e-mail and mail service providers
– technical and support partners, such as the companies who host our website and who provide technical support and back-up services
– professional advisers, such as lawyers, accountants, auditors and insurers, who require such information to provide services to us or for other lawful purposes
– merger or acquisition partners, to the extent that sharing your personal data is necessary
– law enforcement agencies, government or public agencies or officials, regulators, and any other person or entity that has the appropriate legal authority where we are legally required or permitted to do so, to respond to claims, or to protect our rights, interests, privacy, property or safety
any other parties, where we have your specific consent to do so.
Do you have to provide personal data – and, if so, why?
To form a contract with you, we will need some or all of the personal data described above so that we can perform that contract or the steps that lead up to it: this is set out above in this notice. If we do not receive the data, it will not be possible to perform that contract.
If you sign up to our mailing list, you will have to provide certain personal data. Of course, you may decide to stop receiving our mailings at any time.
For how long will your personal data be kept?
We carefully consider the personal data that we store, and we will not keep your information in a form that identifies you for longer than is necessary for the purposes set out in this notice or as required by applicable law. In some instances, we are required to hold data for minimum periods: for example, UK tax law currently specifies a six-year period for retention of some of your personal data.
We may store your contact details, and carry out marketing profiling activities, for direct marketing purposes. If you have given your consent, or if we are otherwise permitted to do so, we may contact you about our services that may be of interest to you. You will be given the opportunity to opt out each time you are contacted.
Do we transfer personal data outside the EEA?
Although we are based in England, we may transfer your personal information to a location (for example, to a secure server) outside the European Economic Area, if we consider it necessary or desirable for the purposes set out in this notice.
In such cases, to safeguard your privacy rights, transfers will be made to recipients to which a European Commission “adequacy decision” applies (this is a decision from the European Commission confirming that adequate safeguards are in place in that location for the protection of personal data), or will be carried out under standard contractual clauses that have been approved by the European Commission as providing appropriate safeguards for international personal data transfers, or by the adoption of EU-US Privacy Shield.
For more information, please contact us as detailed in “Do you want to contact us?” below.
How do we keep your personal data secure?
We have security measures in place designed to prevent data loss, to preserve data integrity, and to regulate access to the data. Only our authorised employees, authorised contractors and third parties processing data on our behalf have access to your personal data.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
We take all reasonable steps to keep your data safe and secure and to ensure the data is accessed only by those who have a legitimate interest to do so. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to us. Any transmission over the internet is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.
Please contact as detailed in “Do you want to contact us?” below if you would like more information about this.
Your information rights
We draw your attention to your following rights under data protection law:
– right to be informed about the collection and use of your personal data
– right of access to your personal data, and the right to request a copy of the information that we hold about you and supplementary details about that information – you will be asked to provide proof of your identify and residential address, and we may ask you to provide further details to assist us in the provision of such information
– right to have inaccurate personal data that we process about you rectified – we want to ensure that the personal information that we process and retain about you is accurate, so please do remember to tell us about any changes, for example if you have moved house or changed your contact details. It is your responsibility to ensure you submit true, accurate, and complete information to us – and please also update us if this information changes
– right of erasure – in certain circumstances you have the right to require us to block, erase or destroy personal data that we process about you
– right to object to, or restrict:
– processing of personal data concerning you for direct marketing decisions being taken by automated means which produce legal effects concerning you or that similarly significantly affect you in certain other situations, our continued processing of your personal data
– the right of portability of your data in certain circumstances.
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 may refuse to comply with your request in these circumstances.
Please contact us as detailed in “Do you want to contact us?” below if you would like to know more about, or to exercise, these rights.
These rights are subject to certain limitations that exist in law. Further information about your information rights is available on the ICO’s website: https://ico.org.uk/.
Changes to this privacy notice
We may change this notice from time to time. You should check this notice on our website occasionally, in order to ensure you are aware of the most recent version.
What should you do if you have a complaint?
We hope that you will be satisfied with the way in which we approach and use your personal data.
Should you find it necessary, you have a right to raise a concern with our supervisory authority, the Information Commissioner’s Office: https://ico.org.uk/.
However, we do hope that if you have a complaint about the way we handle your personal data, you will contact us in the first instance using the contact details as detailed in “Do you want to contact us?” below, so that we have an opportunity to resolve it.
Do you want to contact us?
If you would like to contact us about this notice, including if you wish to receive further information about any aspect of it, our details are as follows:
The Ho-So Initiative Ltd
c/o Citroen Wells
1 Devonshire Place
For the attention of: The Directors