Privacy Policy

BACKGROUND: understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is requested on accessing the website and any correspondence with us.

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings: 

“Account”means an account required to access and/or use certain areas and features of Our Site;
“Cookie”means a small text file placed on your computer or device when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below;
“Cookie Law”means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

2. Information About Us

Our Site is operated by Maria Luz Vargas Villalba and Giovanni Milani-Santarpia

Address: Unit 113998, PO Box 6945, London, W1A 6US.

Data Protection Officer email address:

3. What Does This Policy Cover?

This Privacy Policy applies only to your use of our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

4. What Is Personal Data?

Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

5. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

a) The right to be informed about our or collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.

b) The right to access the personal data we hold about you. Part 13 will tell you how to do this.

c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.

d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.

e) The right to restrict (i.e.prevent) the processing of your personal data.

f) The right to object to us using your personal data for a particular purpose or purposes.

g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.

h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

i) Rights relating to automated decision-making and profiling.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.

6. What Data Do You Collect and How?

Depending upon your use of Our Site, we may collect and hold some or all of the personal data set out in the table below, using the methods also set out in the table. Please also see Part 14 for more information about our use of Cookies and similar technologies.

Data CollectedHow We Collect the Data
Identity information such as name, title, date of birth, gender.This information shall be collected if provided by you: As part of a sign-up process, subscription, purchasing or other form entries which enable provision of our services.When contacting us about any matter you wish to discuss you might include this information on your email or letter to enable our response.
Contact information incl: postal address, email address, telephone number(s)This information shall be collected if provided by you: As part of a sign-up process, subscription, purchasing or other form entries which enable provision of our services.When contacting us about any matter you wish to discuss you might include this information on your email or letter to enable our response.
Business information including business name, job title, profession.Our site is typically used by end consumers and would not normally have a need to collect information regarding businesses other than those businesses supporting or enabling our services.   When customers are purchasing goods, we might ask for insight regarding their interests and reasons linked to the purchase, which may include asking about occupation. This would be through a data collection form.
Payment information including card details or bank details.We use form entry means to process payment and banking information.    We use Stripe for identity document verification. Stripe collects identity document images, facial images, ID numbers and addresses as well as advanced fraud signals and information about the devices that connect to its services. Stripe shares this information with us and also uses this information to operate and improve the services it provides, including for fraud detection, authentication and analytics. You may also choose to allow Stripe to use your data to improve Stripe’s biometric verification technology. You can learn more about StripeStripe Identity, and read its privacy policy at
Profile information including personal preferences, interests, login details, purchase history.Personal preferences such as interests, login details or purchase history are collected through your own direct sharing of such information with us through form entry as may occur as part of signing up to services, account membership or making a purchase. This basic information is then held on a secure database which provides a record from which we can tailor and provide our services more closely to your personal needs.
Technical information such as IP address, browser type and operating systemSuch information may be collected through third party cookies, such as Google Analytics. It is used to help us improve our services through improved understanding of site usage.
Table outlining Data Collection Methods

6.1 How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:

What We  DoWhat Data We UseOur Lawful Basis
Registering you on Our Site.Information such as Title, Name, email address, mailing address, age, gender, occupation and interests.Consent
Providing and managing your Account.Name and email address, correspondence,  Purchase historyConsent
Providing and managing your access to Our Site.Name, user name, passwordLegitimate Interests to improve your experience of the site and access to its information. Security of the site and accounts.
Personalising and tailoring your experience on Our Site.Aggregated usage and browsing analytics data from Google Analytics.Legitimate Interests such as improving the information areas which attract the greatest readership interest.
Administering Our Site.Aggregated usage data from Google Analytics.Legitimate interests to ensure Our Site has sufficient computing resources and is optimally responsive to user activities.
Administering our business.Name, account id, contact details, address, purchasing historyLegitimate Interests such as maintaining business efficiency, financial accounts, security.
Supplying our products and  services to you.Name, contact details, email and physical address, purchase order number, purchase description and supporting details.Contract.
Managing payments for our products and services.Name, banking details such as card, bank address, personal identificationConsent: This information is processed through “Stripe” banking services provider. Stripe legal bases are provided FYI.
Personalising and tailoring our products and services for you.Product personalisation requests. Aggregated usage and browsing analytics.Legitimate interests: using specific information you might provide to customise individual products for you. We also customise the site content and structure as well as products and product suggestions in line with historical aggregated understanding across many site users.
Communicating with you.Name, email or physical address. Details of product purchases or other details you may wish to discuss.Legitimate interests in responding to the queries of customers and other site users.
Supplying you with information by email and/or post that you have opted-in-to (you may opt-out at any time)   Name, physical and/or email address, personal interestsLegitimate interests: Providing and sharing ideas, news and information which you have opted in to receive. This is particularly the case for marketing messages. Service messages do not require opt-in/out as they contain non-promotional information, possibly also safeguarding your own health and safety.
Table showing lawful bases of data collection and processing

With your permission and where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message and/or post with information, news, and offers on our products and/or

services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

Third Parties such as Google, Yahoo or others whose content may appear on Our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

7. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Type of DataHow Long We Keep It
Identity Information including name, title, date of birth, genderUp to 7 years in order to enable eventual tax checks or fraud investigations.
Contact information including address, email, telephone numbers  Up to 7 years in order to enable eventual tax checks or fraud investigations.
Business information including business name, job title, role.Business information is retained as long as there is ongoing interaction and up to a further 7 (seven) years from last interaction to support us with eventual tax reviews or contract claims.
Payment information including name, bank and card details.Payment services within the site are provided by Stripe. As a provider of payment services, Stripe is required to comply with many regulations, including anti-terrorism and anti-money laundering laws. Some of these regulations and laws require Stripe to retain transactional records for a prescribed period of time. You can read more about our underwriting obligations in Stripe’s Privacy Policy and Privacy Center.
Profile information including user name, password, personal interests, page bounce ratesUp to 50 months or as per Google Analytics policies – Further details can be found in the Google Analytics Privacy area
Technical information including IP address, browser type, version, operating systemUp to 50 months or as per Google Analytics policies – Further details can be found in the Google Analytics Privacy area
Table outlining data retention periods

8. How and Where Do You Store or Transfer My Personal Data?

We will store some of your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation.

We will only store or transfer personal data in or to countries that are deemed to provide an adequate level of protection for personal data. For further information about adequacy decisions and adequacy regulations, please refer to the Information Commissioner’s Office.

Please contact us using the details below in Part 15 for further information about the particular data protection safeguard[s] used by us when transferring your personal data to a third country.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

  • minimising the amount of personal data or personally identifiable information
  • taking regular reviews of any information held.
  • limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
  • procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we arelegally required to do so.

9. Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exception[s].

We may sometimes contract with the following third parties to supply certain productsand/orservices. For example, this could include banking transaction services, drop-shipping or courier services involved with fulfilling any products you may purchase.

RecipientActivity Carried OutSectorData typesLocation
Computing infrastructure servicesStorage and maintenance of computing, data and security services.ITAllEU (Spain)
Banking services (Provided by Stripe)Banking details verification and transaction processingBankingBanking transaction information necessary for product purchase transactions.US
Drop-shipping companiesOrder fulfillment networks minimising product inventory, shipping and storage. Products are often made to order and shipped directly from producer to end customer.Retail and Household ItemsName, product, shipping addressUS/UK + Global affiliates according to location of product manufacture and storage in correspondence with customer location. Typically will involve US, UK, EU, Can, Aus, China.
Courier and postal servicesDelivery of goods, parcels and physical mail.LogisticsName, product, shipping addressUS/UK + Global according to location of product manufacture and storage in correspondence with customer location. Typically will involve US, UK, EU, Can, Aus, China.
Site usage analytics (Google Analytics)Collect data (through cookies), analyse and produce aggregated reports on site usage.Website data analyticsIP address, location, browsing, page actions (according to cookie consent)US
Advertising (Google Adsense)Place advertising on the site.Ad placementIP address, location, browsing (according to cookie consent)US
Table outlining sharing and exporting of data

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

If any of your personal data is shared with a third party, as described above we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.

If any personal data is transferred we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 9.

10. How Can I Control My Personal Data?

10.1 In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by at the point of providing your details or unsubscribing using the links provided in our emails.

10.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing from anyone. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

11. Can I Withhold Information?

You may access many areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data

You may restrict our use of Cookies. For more information, see Part 14.

12. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests (commonly referred to as “SAR”) should be made in writing and sent to the email and/or postal addresses shown in Part 14.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept informed of our progress.

13. How Do You Use Cookies?

Our Site may place and access certain Cookies on your computer or device, these are typically referred to a First-party or Third-party Cookies. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our products and/or services . By using Our Site you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us, for example by Google. These third-party cookies and services help us understand how the website is used, which pages and information is more or less popular. Third-party Cookies are used on Our Site to help understand and make educated guesses at how to improve the user experience. For more details, please refer to our Cookie Policy

14. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of The Data Privacy Officer):

  • Email address:
  • Postal Address: The Data Privacy Officer, Unit 113998, PO Box 6945, London, W1A 6US.

You may also fill and submit the Subject Access Request Form

15. Changes to this Privacy Policy

We may change this Privacy Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on 23rd December 2022.


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