This Privacy Policy describes how www.metropot.co.uk (the “Site” or “we”) collects, uses, and discloses your Personal Information when you visit or make a purchase from the Site.

Using Personal Information

We use your personal Information to provide our services to you, which includes: offering products for sale, processing payments, shipping and fulfillment of your order, and keeping you up to date on new products, services, and offers.

Lawful basis

Pursuant to the General Data Protection Regulation (“GDPR”), if you are a resident of the European Economic Area (“EEA”), we process your personal information under the following lawful bases:

• Your consent;
• The performance of the contract between you and the Site;
• Compliance with our legal obligations;
• To protect your vital interests;
• To perform a task carried out in the public interest;
• For our legitimate interests, which do not override your fundamental rights and freedoms.

Retention

When you place an order through the Site, we will retain your Personal Information for our records unless and until you ask us to erase this information. For more information on your right of erasure, please see the ‘Your rights’ section below.

Automatic decision-making

If you are a resident of the EEA, you have the right to object to processing based solely on automated decision-making (which includes profiling), when that decision-making has a legal effect on you or otherwise significantly affects you.

We [DO/DO NOT] engage in fully automated decision-making that has a legal or otherwise significant effect using customer data.

Our processor uses limited automated decision-making to prevent fraud that does not have a legal or otherwise significant effect on you.

Services that include elements of automated decision-making include:

• Temporary denylist of IP addresses associated with repeated failed transactions. This denylist persists for a small number of hours.
• Temporary denylist of credit cards associated with denylisted IP addresses. This denylist persists for a small number of days.

[INCLUDE THE FOLLOWING SECTION ONLY IF YOU SELL PERSONAL INFORMATION, AS DEFINED BY THE CALIFORNIA CONSUMER PRIVACY ACT]

Who we are
This website https://metropot.co.uk/ (the “Website”) is owned and operated by Neatown Ltd.  (registered in England and Wales under company number 08922125, registered at 118 Windmill Road, Croydon, CR0 2XQ) (called in this notice “we”, “our” or “us”).

Purpose of this notice
This privacy notice tells you about the information we collect about you when you visit our Website or otherwise provide us with information.
It also tells you how you can exercise your rights (including the right to object to some of the data handling we carry out). More information about your rights and how you can exercise them is set out in the “Your Rights” section below.

 What personal data do we collect?

Site traffic data and information about your computer

How do we use this data?
When you browse our Website, we use cookies to collect:
• Information about your use of our Website – we collect standard internet log information and details of visitor behaviour patterns.
– We use this information to record visitor numbers, their use of different areas of the Website and any useful features or links. We do not use this information in any way that would identify you personally.
– We use a third party, Google Analytics, to collect this information but it is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website;

• Information about your computer; includes your IP address, operating system and browser type.
  – We use this information to help maintain the security of our Website and to identify trends so that we can improve its performance.
  – We also use this information to customize the Website according to your interests and to ensure the Website’s content is presented as effectively as possible for you.
  – We do not use this information in any way that would identify you personally.

Data we collect using non-essential cookies is used on the basis of your consent. Any other information that we collect about your use of our Website is used on the basis that this is necessary for the purpose of our legitimate interests in maintaining and managing our Website and ensuring its security.

For more information about how we use cookies on our Website, see our Cookies Policy.

How long do we keep this information for?
We will only keep information about your visit to our Website for as long as is necessary for the purposes we’ve mentioned. Typically, we delete user browsing information every 12 months. See our Cookies Policy for further information.

Who do we share this information with?
We share information about visitors to our Website with service providers who help us administer and manage the Website.
We also share information about your use of our Website with advertising networks, although you cannot be personally identified from this information.

Where do we transfer this information to?
Information we collect about your use of our Website is stored within, and not transferred outside of, the United Kingdom.

Collecting Personal Information

When you visit the Site, we collect certain information about your device, your interaction with the Site, and information necessary to process your purchases. We may also collect additional information if you contact us for customer support. In this Privacy Policy, we refer to any information that can uniquely identify an individual (including the information below) as “Personal Information”. See the list below for more information about what Personal Information we collect and why.

Device information

• Examples of Personal Information collected: version of web browser, IP address, time zone, cookie information, what sites or products you view, search terms, and how you interact with the Site.
• Purpose of collection: to load the Site accurately for you, and to perform analytics on Site usage to optimize our Site.
• Source of collection: Collected automatically when you access our Site using cookies, log files, web beacons, tags, or pixels.
• Disclosure for a business purpose: shared with our processor

Order information

• Examples of Personal Information collected: name, billing address, shipping address, payment information (including credit card numbers [INSERT ANY OTHER PAYMENT TYPES ACCEPTED]), email address, and phone number.
• Purpose of collection: to provide products or services to you to fulfill our contract, to process your payment information, arrange for shipping, and provide you with invoices and/or order confirmations, communicate with you, screen our orders for potential risk or fraud, and when in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.
• Source of collection: collected from you.
• Disclosure for a business purpose: shared with our processor.

Customer support information

• Examples of Personal Information collected: [MODIFICATIONS TO THE INFORMATION LISTED ABOVE OR ADDITIONAL INFORMATION AS NEEDED]
• Purpose of collection: to provide customer support.
• Source of collection: collected from you.
• Disclosure for a business purpose: [ADD ANY VENDORS USED TO PROVIDE CUSTOMER SUPPORT]

[INSERT ANY OTHER INFORMATION YOU COLLECT: OFFLINE DATA, PURCHASED MARKETING DATA/LISTS]

[INSERT FOLLOWING SECTION IF AGE RESTRICTION IS REQUIRED]

Minors

The Site is not intended for individuals under the age of [INSERT AGE]. We do not intentionally collect Personal Information from children. If you are the parent or guardian and believe your child has provided us with Personal Information, please contact us at the address below to request deletion.

Sharing Personal Information

We share your Personal Information with service providers to help us provide our services and fulfill our contracts with you, as described above. For example:

• We may share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
• [INSERT INFORMATION ABOUT OTHER SERVICE PROVIDERS]

[INCLUDE FOLLOWING SECTION IF USING REMARKETING OR TARGETED ADVERTISING]

Behavioural Advertising

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For example:

• [INSERT IF APPLICABLE] We use Google Analytics to help us understand how our customers use the Site. You can read more about how Google uses your Personal Information here: https://policies.google.com/privacy?hl=en.You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
• [INSERT IF YOU USE A THIRD PARTY MARKETING APP THAT COLLECTS INFORMATION ABOUT BUYER ACTIVITY ON YOUR SITE] We share information about your use of the Site, your purchases, and your interaction with our ads on other websites with our advertising partners. We collect and share some of this information directly with our advertising partners, and in some cases through the use of cookies or other similar technologies (which you may consent to, depending on your location).
• [INSERT OTHER ADVERTISING SERVICES USED]

For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by:

[INCLUDE OPT-OUT LINKS FROM WHICHEVER SERVICES BEING USED. COMMON LINKS INCLUDE:

• FACEBOOK - https://www.facebook.com/settings/?tab=ads
• GOOGLE - https://www.google.com/settings/ads/anonymous
• BING - https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads]

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

Your rights

GDPR

If you are a resident of the EEA, you have the right to access the Personal Information we hold about you, to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through the contact information below.

Your Personal Information will be initially processed in Ireland and then will be transferred outside of Europe for storage and further processing, including to Canada and the United States. For more information on how data transfers comply with the GDPR, see our processor's GDPR Whitepaper: https://help.shopify.com/en/manual/your-account/privacy/GDPR.

CCPA

If you are a resident of California, you have the right to access the Personal Information we hold about you (also known as the ‘Right to Know’), to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through the contact information below [OR INSERT ALTERNATIVE INSTRUCTIONS FOR SENDING ACCESS, ERASURE, CORRECTION, AND PORTABILITY REQUESTS].

If you would like to designate an authorized agent to submit these requests on your behalf, please contact us at the address below.

Cookies

A cookie is a small amount of information that’s downloaded to your computer or device when you visit our Site. We use a number of different cookies, including functional, performance, advertising, and social media or content cookies. Cookies make your browsing experience better by allowing the website to remember your actions and preferences (such as login and region selection). This means you don’t have to re-enter this information each time you return to the site or browse from one page to another. Cookies also provide information on how people use the website, for instance whether it’s their first time visiting or if they are a frequent visitor.

We use the following cookies to optimize your experience on our Site and to provide our services.

Cookies Necessary for the Functioning of the Store

Name	Function
_ab	Used in connection with access to admin.
_secure_session_id	Used in connection with navigation through a storefront.
cart	Used in connection with shopping cart.
cart_sig	Used in connection with checkout.
cart_ts	Used in connection with checkout.
checkout_token	Used in connection with checkout.
secret	Used in connection with checkout.
secure_customer_sig	Used in connection with customer login.
storefront_digest	Used in connection with customer login.
_shopify_u	Used to facilitate updating customer account information.

The length of time that a cookie remains on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies last until you stop browsing and persistent cookies last until they expire or are deleted. Most of the cookies we use are persistent and will expire between 30 minutes and two years from the date they are downloaded to your device.

You can control and manage cookies in various ways. Please keep in mind that removing or blocking cookies can negatively impact your user experience and parts of our website may no longer be fully accessible.

Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls, often found in your browser’s “Tools” or “Preferences” menu. For more information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser’s help file or through such sites as www.allaboutcookies.org.

Additionally, please note that blocking cookies may not completely prevent how we share information with third parties such as our advertising partners. To exercise your rights or opt-out of certain uses of your information by these parties, please follow the instructions in the “Behavioural Advertising” section above.

Do Not Track

Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.

Changes

We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons.

Contact

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at [email address] or by mail using the details provided below:

5 New Bridge Street, London EC4V 6AB, United Kingdom

Last updated: [DATE]

If you are not satisfied with our response to your complaint, you have the right to lodge your complaint with the relevant data protection authority. You can contact your local data protection authority, or our supervisory authority here: [ADD CONTACT INFORMATION OR WEBSITE FOR THE DATA PROTECTION AUTHORITY IN YOUR JURISDICTION. FOR EXAMPLE: https://ico.org.uk/make-a-complaint/]