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This Privacy & Cookies Policy governs the use by Caffè Nero Group Ltd of the personal data we collect from you during your use of the website located at www.caffenero.com (the “Site”) or we otherwise obtain about you (“Personal Information”).

In this Policy, ” Caffè Nero”, “we”, “us” and “our”, refer to Nero Holdings Ltd.

Caffè Nero Group Ltd is committed to protecting the security and privacy of third parties (including its customers and all visitors to the Site. We will comply with the requirements of the “Data Protection Legislation”, including (i) the UK Data Protection Act 1998, (ii) from 25 May 2018, the EU General Data Protection Regulation (which will replace the Data Protection Act 1998), (iii) the Privacy and Electronic Communications (EC Directive) Regulations 2003 and (iv) all similar or related legislation relating to the processing of Personal Information and/or privacy applicable in any jurisdiction and will take reasonable steps to ensure that your Personal Information is secure, and monitored with regard to access, both internally and externally.

We will only collect your Personal Information:

1. when you give feedback to this site;
2. when you purchase products from the site;
3. when you join, sign up or subscribe to any of our clubs, panels, forums or other facilities which we run on or from the Site from time to time;
4. through cookies; and
5. through data aggregation.

Please note: from July 2020 Nero Holdings Ltd introduced a data collection service to assist the NHS in England, Scotland, Wales and Northern Ireland with the COVID-19 contact tracing schemes. This service will be in operation only for as long as the relevant government guidance remains in place. The personal data collected through this service is limited to that specified in the relevant government guidance and will be retained for 21 days. Access to the data will be limited to system administrators. The data you submit through this system will not be used for any purpose other than the NHS Test and Trace scheme unless explicit consent is given by you. If explicit consent is given, Nero Holdings Ltd will process and retain this data as described, where relevant, in this privacy policy.

We will ensure that your Personal Information is handled in accordance with the Data Protection Legislation. By visiting and/or contacting us through the Website (or otherwise engaging with us), you acknowledge that we may collect, use and transfer your Personal Information as set out in this Policy.

For the purposes of the Data Protection Legislation, we are deemed to be the “data controller” in respect of any Personal Information that you provide to us or we otherwise obtain about you.

This Privacy and Cookie Policy covers:

1. Personal Information that we collect
2. Personal Information that we receive from other sources
3. What we do with your Personal Information
4. How we share your Personal Information
5. Our security measures and information about when we delete data
6. Transferring Personal Information outside of the EEA
7. How you can access and update your Personal Information
8. Complaints
9. Our use of cookies
10. Changes to this Policy
11. Our contact information and opting out

1. PERSONAL INFORMATION THAT WE COLLECT

When you engage with us (e.g. sending us emails, contacting us via telephone or visiting or making an enquiry through the Website), you may provide Personal Information about yourself including your name and contact details (e.g. your address, email address and telephone number) and your job title and CV where you apply for a role with us. If you consider purchasing from us, you may also provide us with various other necessary Personal Information (e.g. your bank details). Where you make use of our Site we may also collect information about your use of the Site (e.g. your IP address and choice of web browser). Some of this Personal Information is collected and processed so we can perform a contract with you, some for the purpose of legal compliance and some for the purposes of our legitimate business interests (namely to carry out and improve our business, analyse the use of our Site and services and support our staff and customers).

Feedback
Where you give feedback to or contact us we will only ever use your Personal Information to respond directly to you in relation to your feedback and/or comment.

Purchases
We will use your Personal Information to provide you with the products you order from us.

Gift cards and Surveys
If you create an account or register a gift card, we will collect data on your username, password, phone number, date of birth, name and address. If you buy goods at our stores using a Gift Card, we will collect data on where you buy, how frequently you buy.

If you take a survey or interact with us in various other ways – name, address, phone number, date of birth and demographics information. We also ask customers if they would like to provide us with their Post Code and Telephone Number.

User Sign-up
If you choose the opt in and sign up to our communications and/or marketing materials, we may collect data on your username, password, contact e-mail address, mailing address, phone number, date of birth, demographics information, and personal interests. Unless you choose to opt out, or communicate the decision to discontinue by contacting us as described below, we will use your Personal Information to send you information which we think may interest you and keep you up to date as to developments relating to the facility operated by us which you have joined, signed-up to or subscribed to.

CCTV
We also have CCTV in some of our stores and offices for the purpose of crime prevention and where this is used, we will display appropriate notices.

2. PERSONAL INFORMATION WE RECEIVE FROM OTHER SOURCES

We may receive information from third parties who collect Personal Information from you and pass it on to us, for example, for fraud prevention. Our staff may also give us emergency contact information as part of our emergency scenario planning and may give us details of their dependents and of other people in relation to their employee benefits arrangements. Where this is the case the third party is responsible for obtaining the relevant consents from you to ensure you are happy with the ways in which your Personal Information will be used.

3. WHAT WE DO WITH YOUR PERSONAL INFORMATION

We will only use your Personal Information in order to:

(a) supply the services you have requested and correspond with you,

(b) provide support to you in respect of these services,

(c) improve our Site and services

(d) for our internal business processes, including providing support to our staff,

(e) where relevant, process your application for employment.

(f) where you have explicitly consented at the time we collected your Personal Information or where we otherwise have a right to do so, we may also use your Personal Information to let you know about our services, and job openings that may be of interest to you and/or inform you about important changes or developments to our services, by post, telephone and e-mail.

(g) from time to time, we may also use your Personal Information to contact you for market research purposes. We may contact you by email, phone or mail. This will only happen where you have opted-in to receive such communications.

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our Site.

We may also use the Personal Information to customise the Site according to your interests.

If you change your mind about us using your Personal Information in the ways described in this Policy, please let us know by contacting us.

You may also opt out of receiving marketing emails from us by following the instructions outlined in any marketing email you receive from us.

4. HOW WE SHARE YOUR PERSONAL INFORMATION

In certain circumstances we may pass your Personal Information to carefully selected third parties. We will never pass your Personal Information for such purposes unless you have allowed us to do so or we have a lawful right to do so.

If after having given us permission to pass your Personal Information to third parties you change your mind you can opt out by contacting us as described below.

By submitting your Personal Information to us, you acknowledge that such third parties may receive and process your Personal Information. Caffè Nero asks all third parties to treat your Personal Information securely and in accordance with this Privacy Policy, and we will take reasonable steps to enforce this. We will never sell your Personal Information.

In addition, it may be necessary to disclose your Personal Information if we are under a duty to disclose your Personal Information in order to comply with any legal obligation, carry out an internal investigation, enforce our Terms and Conditions and any other agreement, or protect the rights, property, or safety of Caffè Nero, Caffè Nero’s group companies and our customers, directors, employees or other personnel. This includes exchanging information with other companies and organisations for the purposes of fraud protection and prevention.

5. OUR SECURITY MEASURES AND INFORMATION ABOUT WHEN WE DELETE DATA

We take steps to protect your Personal Information from unauthorised access and against unlawful processing, accidental loss, destruction and damage.

We will only keep your Personal Information for as long as we reasonably require and, in any event, only for as long as the Data Protection Legislation allows.

Where you have chosen a password which allows you to access certain parts of the Site, 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 and, although we will take steps to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted via the Website; any transmission is therefore at your own risk.

6. TRANSFERRING PERSONAL INFORMATION OUTSIDE OF THE EEA

The Personal Information you provide to us will be transferred to and stored on our servers, which sits within the EEA.

In processing your Personal Information, it will sometimes be necessary for us to transfer your Personal Information outside the European Economic Area (“EEA“) to our staff and our third party service providers. It may also be accessed by staff operating outside the EEA who work for us or for one of our suppliers or group companies. This includes people engaged in, among other things, the provision of support services to us.

We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Policy and the Data Protection Legislation when it is processed in, or otherwise accessed from, a location outside the EEA. This means that we will only transfer your Personal Information to third parties based outside the EEA if that party:

(a) is situated in a country that has been confirmed by the European Commission to provide adequate protection to Personal Information,

(b) has agreed (by way of written contract) to provide all protections to your Personal Information as required by the Data Protection Legislation or,

(c) we have your explicit consent to do so (such as where you have requested a service from one of our partners situated outside the EEA). Where any transfer takes place under a written contract, you have the right to request a copy of that contract and may do so by contacting us at Caffè Nero.

For the avoidance of doubt, in the event that the UK is no longer a part of the EEA, references in this paragraph to the EEA shall mean the EEA and the UK.

7. ACCESSING AND UPDATING YOUR PERSONAL INFORMATION

You have the right to ask us not to process your Personal Information for marketing or research purposes. We will usually inform you (before collecting your Personal Information) if we intend to use your Personal Information for such purposes or if we intend to disclose your Personal Information to any third party for such purposes.

You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your Personal Information. If you wish to see your data, you may also complete this form. Your request will be processed within 30 calendar days upon receipt of a fully completed form and proof of identity may be required. You can also exercise the right at any time by contacting us at the details set out as below.

You have the right to see the Personal Information we hold about you and to ask us to:

(a) make any changes to ensure that any Personal Information we hold about you is accurate and up to date;

(b) erase or stop processing any Personal Information we hold about you where there is no longer a legal ground for us to hold it; or

(c) in some cases, transfer any information we hold about you to a specified third party.

(d) we will, within the legally required timeframe, provide you with a complete list of all the personal data held on you upon request.

If you wish to exercise any of these rights, please contact us at Caffè Nero /using the contact details as described below.

8. COMPLAINTS

Should you have any queries or complaints in relation to how we use your Personal Information, please contact us at Caffè Nero /using the details set out as described below. Should you wish to take any complaints or queries further, you have the right to contact the Information Commissioner’s Office regarding such issues.

Our Site may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites or their related policies. Please check these policies before you submit any Personal Information via these websites.

9. OUR USE OF COOKIES

A cookie is a small file that is sent to your browser from a web server and is stored on your computer. Cookies help us to analyse web traffic and identify which pages of our Site are being used. Our Site also uses cookies to respond to you as an individual so that it can tailor its operations to your needs by gathering and remembering information about your preferences as well as enabling you to login to your account. We only use this information for statistical analysis purposes and then it is removed from our systems.

A cookie in no way gives us access to your computer or any information about you, other than information about how you use the Site and the Personal Information you choose to share with us (including Personal Information you automatically share with us by way of your browser settings).

To enable us to monitor and improve the Site, we gather certain aggregated information about you when you use it, including details of your operating system, browser version, domain name and IP address, the URL you came from and go to and the parts of our Site you visit. We may aggregate statistics, traffic patterns and related site information and disclose such aggregate data to third parties for marketing, advertising or other promotional purposes but such aggregate data will not include any Personal Information.
For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve our site and to deliver a better and more personalised service.

In particular, we use the following cookies:

• Strictly necessary cookies. These cookies are essential in order to enable you to move around the Site and use its features, such as accessing secure areas.
• Performance cookies. These cookies collect information about how visitors use our Site, for instance which pages visitors go to most often and if they get error messages from the web pages. These cookies don’t collect information that identifies a visitor; all information these cookies collect is aggregated and therefore anonymous. It is only used to improve how our Site works.
• Functionality cookies. These cookies allow our Site to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of the Site that you can customise. The information these cookies collect is anonymised and they cannot track your browsing activities on other websites.
• Sharing cookies. These cookies allow you to interact with third party services such as Caffè Nero. Information collected by these cookies is aggregated and therefore anonymous.

You will normally see a message on our Site before we store a cookie on your computer. We may also use banners and pop-ups from time to time to give you options around cookies use.

You can also manage cookie use via your browser settings (this will allow you to refuse the setting of all or some cookies) and your browser provider may ask you to confirm your settings. Note, however, that if you block all cookies (including essential cookies) via your browser settings you may not be able to access all or parts of our Site.

You can also find more information about cookies generally here: www.allaboutcookies.org.

Please note that third party providers may also use cookies to assess the ways in which you make use of their websites and we have no control over these.

10. CHANGES TO OUR PRIVACY AND COOKIES POLICY

Caffè Nero may amend this Policy at any time without notice. By continuing to use the Website and making use of our services you agree to the updated Policy. If you do not agree to any changes that we make, you should not use or access (or continue to use or access) the Site and/or our services. Any changes to this Policy will be posted on the Site.

11. OUR CONTACT INFORMATION AND OPTING OUT

You can opt out of receiving various communications from us by contacting us through our contact us page.

If you have any questions (including relating to transfers of your Personal Information outside the EEA), please feel free to contact us by email at enquiries@caffenero.com. If you wish to see your data, you may also complete this form. Your request will be processed within 30 calendar days upon receipt of a fully completed form and proof of identity may be required. Alternatively, you may call our team on +44 (0)20 7520 5150 , Monday to Friday: 9am to 5pm.

UK, 18+ only. 00:01 17/02/22 – 23:59 17/03/22. Purchase any handcrafted drink on the Caffe Nero app and answer the riddle correctly to find out instantly if you have won a Prize. Purchase required. Prizes: 2022 prizes available to be won. 1 x Three course meal with a drink at Park Row, London, 1 x Tech bundle made up of 1 x In-ear headphones with charging case and 1 x Smart Sound Bar with Dolby Atmos & Voice Control, 500 x Complimentary drinks, 1500 x Complimentary mystery drinks, 100 x Batman branded backpacks and 100 x Bluetooth earphones. Internet access and Caffe Nero app required. Visit www.caffenero.com/thebatman for full T&Cs and Prize details. Promoter: Caffe Nero, 9-15 Neal Street, London, WC2H 9PW

Full Terms and Conditions:

1. This Promotion is open to residents of the United Kingdom aged 18 or over, excluding anyone professionally associated with this Promotion.

2. Purchase is necessary. Internet access and the Caffe Nero app are required.

3. Promotion Period: Enter between 00.01 GMT on the 17 February 2022 and 23.59 GMT on the 17 March 2022 inclusive.

4. To Enter: Purchase any handcrafted drink on the Caffe Nero app and answer the riddle correctly to find out instantly if you have won a Prize.

5. Entrants can enter unlimited times during the Promotion Period provided they make a new qualifying purchase and correctly answer the riddle. Entrants can win unlimited prizes.

6. Winner Selection:

   Instant Win: During the Promotion Period 1553 winners will be randomly selected from all valid entries via an independent algorithm process which will award a Prize immediately if a winner is selected.

7. Instant Win Prizes: During the Promotion Period, there are a total of 2022 Prizes to be won.
   1. 1 x Three course meal with a drink at Park Row, London.
   2. 1 x Tech bundle made up of 1 x In-ear headphones with charging case and 1 x Smart Sound Bar with Dolby Atmos & Voice Control
   3. 500 x Complimentary drinks
   4. 1500 x Complimentary mystery drinks
   5. 100 x Batman branded backpacks
   6. 100 x Bluetooth earphones

8. Further Prize Details and Conditions:
   1. The meal will be at Park Row, London.
   2. The total cost of the meal can be up to £550.
   3. The restaurant dress code is smart casual.
   4. The winner can choose when they take the Prize.
   5. The complimentary drinks will be any Caffe Nero handcrafted drink including extras and speciality drinks.
   6. The winner is responsible for the behaviour of themselves and their guests whilst taking the Prize. The Promoter reserves the right in its absolute discretion to exclude the winner and/or their guests from participation in any aspect of the Prize if any party fails to comply with the directions of the Promoter or any companies associated with the Prize or if the winner and/or their guests act in a manner that is dangerous to themselves or to the public or is, in the opinion of the Promoter, anti-social in any manner or which causes a disturbance or nuisance to others. Failure to comply with these Terms and Conditions may result in refused entry, or the ticket holders being required to leave the event/venue.
   7. You and your guest must abide by any relevant terms and conditions which form part of the prize. Whilst at the event/venue, you must not: be drunk, intoxicated, under the influence of drugs, underage, be abusive, threatening, make or incite racial abuse, chant, use offensive language, make obscene gestures, throw items, behave anti-socially, carry laser pens, bring animals (except guide dogs), carry offensive weapons or illegal substances, carry candles, climb any structure, make excessive noise, offer any item for sale, damage the venue or smoke. Failure to comply with these Terms and Conditions may result in refused entry, or the ticket holders being required to leave the event/venue.
   8. You and your guest must abide by any relevant terms and conditions set by the venue/s which form part of your prize. It is your responsibility to ensure that you take care when moving around the event/venue.
   9. Redemption of all Prizes is subject to Government guidelines and lockdown measures which can be found at: https://www.gov.uk/coronavirus.
   10. If Government guidelines restrict redemption of the Prize in its current form, the Promoter will work with the winner to discuss moving the prize to a later date or issuing an alternative prize.
   11. At all times, the Promoter will have the discretion as to how to implement the Prize fulfilment.

9. Winner Notification:
   1. Instant Win: The winning entrants will be instantly notified on screen and asked to follow the instructions immediately to claim their Prize. If a winner does not follow the instructions, the Promoter reserves the right to disqualify that winner..

10. Prize Acceptance: Winners will be notified within 28 days of acceptance of the Prize to arrange fulfilment of the Prize. In the unlikely event that a winner does not receive their notification within 28 days, the winners will have a further 28 days to inform the Promoter by emailing uk.customersupport@caffenero.com. If a winner does not do so, the Promoter reserves the right to not reissue the Prize or limit its value at its sole discretion.

11. Provided no objection from the winners is received, a winners list will be made available by the Promoter 4 weeks after the close of the Promotion Period, for a period of 8 weeks. It will be at www.caffenero.com/thebatman. Winners can object to their surname or county of residence being published or request for the amount of information being published to be reduced during the Winner Notification process. However, without prejudice, the Promoter will provide winner information to the Advertising Standards Authority on reasonable request.

12. The Promoter may request that the winners participate in reasonable publicity arising from the Promotion. Participation is at the winner’s discretion and is not a condition of Prize Acceptance.

13. The Promoter seeks to run a fair and secure promotions and prevent abuse and cheating. If you enter in a way that is not consistent with these Terms & Conditions, your entries (and any of your associated aliases) will be disqualified, any Prize awarded may be void and recoverable, and the Promoter reserves the right to bar you from entering future promotions for a period of at least six months. For this reason, the Promoter reserves the right at any point to:

1. Verify the eligibility of entrants and/or provisional winners by requesting such information we consider reasonably necessary for this purpose. Entry or a Prize may be withheld unless and until verification is completed satisfactorily.
2. Disqualify entries that are not made directly by the individual entering the Promotion.
3. Disqualify entries made using anonymous email services such as, but not limited toGuerillaMail, Dispostable or Mailinator.
4. Disqualify bulk entries from individuals, trade, consumer groups or third parties, incomplete entries and entries submitted by macros or other automated means.
5. Disqualify entries beyond the maximum allowed, or those using techniques such as ‘script’, ‘brute force’, multiple SIM cards for Text entries, masking identity by manipulating IP addresses, using aliases or identities other than their own or any other means.
6. Disqualify entries which, in some other way, do not fully meet the requirements of these Terms & Conditions.

14. The Prizes are not transferable or exchangeable and cannot be redeemed for monetary value or for any other form of compensation. If for any reason any Prize is not available, the Promoter reserves the right, at its sole discretion to substitute another Prize for it, of equal or greater value.

15. If the Promotion is not capable of running as planned for reasons including but not limited to tampering, unauthorised intervention, fraud, dishonesty, technical failures, or any other causes beyond the control of the Promoter which corrupt or affect the administration, security, fairness, integrity or proper conduct of this Promotion, the Promoter reserves the right to disqualify any individual who tampers with the entry process or does not comply with these Terms & Conditions, or invalidate any affected entries and/or to cancel, modify or suspend the Promotion.

16. No responsibility can be taken for entries which are lost, delayed, corrupted, damaged, misdirected or incomplete or which cannot be delivered for any technical, delivery or other reason. Proof of sending will not be accepted as proof of receipt. The Promoter does not guarantee continuous or secure access to the Caffe Nero app.

17. The Promoter and its associated agencies and companies are not liable for any loss (including, without limitation, indirect, special or consequential loss or loss of profits), expense or damage which is suffered or sustained (whether or not arising from any person’s negligence) in connection with this Promotion or accepting or using a Prize, except for any liability which cannot be excluded by law. Nothing will exclude the Promotor’s liability for death or personal injury as a result of its negligence.

18. The Promoter will not be liable for any delay or failure to comply with its obligations for reasons beyond its reasonable control arising from but not limited to Acts of God, global or regional epidemic or pandemic, adverse weather conditions, fire, industrial dispute, war, terrorist activity, hostilities, political unrest, riots, civil commotion, plague or other natural calamities, or any other circumstances of the Promoter.

19. All personal data supplied for this Promotion will be used solely for the purpose of this Promotion by the Promoter and/or by any agent appointed by it to assist with running the Promotion and will not be disclosed to an unconnected third party unless your positive consent has been obtained. Your personal data will be handled in accordance with the Promoter’s privacy policy, available at: https://caffenero.com/uk/privacy-policy

20. If any part of these Terms & Conditions are legally ruled to be invalid, illegal or unenforceable, the remainder will not be affected and will continue in full force and effect.

21. By entering, you will be deemed to have agreed to be bound by these Terms & Conditions.

22. If there is a discrepancy between these Terms & Conditions and those in any promotional material, these Terms & Conditions will prevail.

23. These Terms & Conditions are governed by English law and their interpretation and application will be subject to the exclusive jurisdiction of the courts of England and Wales.

Promoter: Caffe Nero, 9-15 Neal Street, London, WC2H 9PW