Privacy Policy

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

For the purposes of this Privacy Policy:

• Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Privacy Policy) refers to SIA “FINOX”, registration number 40203379555, registered address:  Skanstes Street 25, Riga, LV-1013, Latvia.
• Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
• Data Controller for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
• Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
• EU GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (EU General Data Protection Regulation).
• Personal Data is any information that relates to an identified or identifiable individual. For the purposes of GDPR, Personal Data means any information relating to You, for example, name, surname, identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
• Service refers to the Website.
• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• Website refers to teahouseclub.com.
• You, Your – an identified or identifiable individual (i.e. a Data Subject as defined in the UK GDPR, EU GDPR, UK Data Protection Act 2018 as applicable) who is applying, accessing or using Our services either on his or her own account or on behalf of a corporate entity. This includes an individual acting as an existing customer or as a prospective customer of Company, or an individual acting on behalf of a corporate entity, including any principals (managing and financial directors, other directors and officers, shareholders, partners and beneficial owners of the corporate entity), as well as any member of staff or an employee accessing or using Our services on behalf of a corporate entity.

The data controller for the processing of Personal Data is SIA “FINOX”, registration number 40203379555, registered address:  Skanstes Street 25, Riga, LV-1013, Latvia.

The Company’s contact information for matters related to personal data processing is: [email protected]. By using this contact information or addressing the Company’s legal address with a written submission, questions regarding the processing of Personal Data may be asked.

The Company protects the privacy and security of Personal Data held by the Company. The Company processes and stores only data that has been lawfully obtained and is necessary for the Company’s operations, compliance with regulatory requirements, and fulfilment of contractual obligations. By visiting and using the website https://teahouseclub.com/, visitors agree to the terms of this Privacy Policy, including the described methods of using cookies.

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address
• Bank account information in order to pay for products and/or services within the Service
• Usage Data

When You pay for a product and/or a service via bank transfer, We may ask You to provide information to facilitate this transaction and to verify Your identity. Such information may include, without limitation:

• First name and last name
• Date of birth
• Passport or National ID card
• Bank card information
• Address

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. 

• Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
• Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

Necessary / Essential Cookies

• Type: Session Cookies
• Administered by: Us
• Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

Cookies Policy / Notice Acceptance Cookies

• Type: Persistent Cookies
• Administered by: Us
• Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

Functionality Cookies

• Type: Persistent Cookies
• Administered by: Us
• Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

Tracking and Performance Cookies

• Type: Persistent Cookies
• Administered by: Third-Parties
• Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new pages, features or new functionality of the Website to see how our users react to them.

We have a legal basis (a valid legal reason) for processing Your personal information. A valid legal basis can be any of the following:

• Fulfil contractual obligations. We need certain personal information to provide our services and cannot provide them without this information.
• Comply with laws. In some cases, We have a legal responsibility to collect and store Your personal information.
• Legitimate interests. Sometimes we collect and use Your personal information, or share it with other organizations, because we or they have a legitimate reason to have it and this is reasonable when balanced against Your right to privacy.
• Consent. Where You’ve agreed to Company collecting Your information, for example, by using Website or when You have ticked a box to indicate You, You are happy for us to use Your personal information in a certain way.

• To provide and maintain our Service, including to monitor the usage of our Service.
• To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
• To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
• To manage Your requests: To attend and manage Your requests to Us.
• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

The company implements the necessary measures to process Your personal data in compliance with relevant laws and regulations and to guarantee that the Your personal data is not disclosed to third parties without a relevant legal justification. However, You are responsible for the consequences if You allow third parties to access the Personal Data stored in Your account.

• Employees of the Company or directly authorized persons who need it for the performance of work duties;
• Sellers or service providers from whom You buy goods or receives services. In this case, Personal data will be processed in accordance with the procedure established by the seller or service provider, as well as in accordance with the contractual security obligations of the Company and the seller or service provider regarding the security of personal data;
• Data processors authorized by the Company (companies that process data on behalf of the Company). In such cases, the Company takes the necessary measures so that the authorized data processors perform data processing in accordance with the Company’s instructions, comply with the necessary security and confidentiality requirements, as well as act in accordance with the requirements set forth in the regulatory acts;
• In the cases specified in the legal acts of state and municipal authorities, for example, law enforcement authorities, municipalities, tax administrations, sworn bailiffs;
• Third parties, after careful consideration of whether there is an appropriate legal basis for such transfer of data, such as courts, out-of-court dispute resolution bodies, insolvency administrators and other third parties.

If We need to transfer Your personal data to a third country (i.e. a country outside the UK or the EEA respectively), we will do it under one of the following conditions:

• The destination country has been recognised by the United Kingdom or the European Commission respectively as ensuring an adequate level of personal data protection (i.e. there is an “Adequacy decision” in relation to this country);
• Other appropriate safeguards exist for the data transfer (including but not limited to binding corporate rules, standard data protection clauses in the cooperation agreement or an approved code of conduct, in accordance with Article 46 of UK GDPR and EU GDPR).

In the absence of the above safeguards, in cases allowed by the applicable legislation including if You have given Your explicit consent for the transfer or if the transfer is needed for: 

• the performance of a contract between You and us; 
• conclusion or performance of a contract concluded in Your interest; 
• establishment, exercise or defense of legal claims;
• important reasons of public interest.

You may request information regarding specific safeguards by contacting Us.

Personal data will be processed for as long as is necessary to achieve the specific purpose of the processing. The retention period is reasonable as long as at least one of the following circumstances exists:

• Personal Data necessary for the performance of a contractual obligation will be retained until the contract has been performed and until other retention periods have been met;
• Personal Data that needs to be retained to comply with laws and regulations will be retained for the periods specified in the relevant laws and regulations;
• For as long as Your consent to the processing of personal data is valid, in the absence of any other lawful basis for processing;
• Data for the purpose of proving the performance of obligations will be stored taking into account the limitation period for claims in accordance with the limitation periods for claims set out in the relevant laws and regulations.

Upon termination of all of the above circumstances, the Personal Data shall be deleted in such a way that it would be impossible with reasonable efforts to restore the data. The Company shall not separately inform the Data Subject of such deletion.

We ensure the correctness of Personal Data, according to the information that comes to our disposal when you use our services, or by independently submitting a request to supplement or update your personal data, presenting documents justifying the changes. If you stop using our services and the mutually concluded contract is terminated or terminated in any other way, we start recording the period after which the data will be destroyed and do not require you to submit information for updating the data.

Right to be informed. You have the right to be informed about how we process Your information. We do this through this Privacy Policy, other information on our Website, and by answering Your questions sent to us.

Right to access Your data. You may request a copy of Your data if You would like to know what personal data we process about You. This copy of Your personal data can also be transmitted in a machine readable format (i.e. “data portability”).

Right to rectification. You have the right to correct inaccurate or incomplete information we hold about You.

Right to erasure. You have the right to request deletion of Your personal data, for example, when it is no longer necessary for us to process the data for the purpose it was collected, or when You have withdrawn Your consent. However, there may be certain legal obligations preventing us from immediately deleting some of Your Personal Data.

Right to restrict processing of Your data or object to our processing. If You believe Your information is incorrect or You believe we use Your data unlawfully, You have the right to ask us to stop the processing. You may also object to our processing where You believe there are circumstances that would make such processing unlawful. Furthermore, You can always object to us using Your data for direct marketing.

Right to challenge an automated decision. You have the right to challenge an automated decision made by Company if this decision carries with it legal or similarly significant effects. 

Right to withdraw consent. Where we process Your data based on Your consent or explicit consent, You may withdraw this consent at any time. 

Right to lodge a complaint. We encourage You to contact us if You have any questions in relation to the present Privacy Policy. In case You have not received a satisfactory reply or solution from us, however, You have the right to lodge a complaint with Your national supervisory data protection authority. Complaints to the UK supervisory authority (the Information Commissioner) can be made using this link: https://ico.org.uk/make-a-complaint/ 

You may submit a request for the exercise of Your rights in writing by submitting a submission in electronic form or by sending a written application to Flat 104 Nokes Court Commonwealth Drive, Crawley, England, RH10 1AN.

Before providing information about Your data, we must make sure that you are the true subject of the personal data to whom the request or application applies.

Upon receiving your request and ascertaining your identity, we shall provide You with an answer within one month from the moment of receiving the application. We will send the answer to You by mail to the contact address indicated by You in a registered letter or by e-mail, taking into account the desired response indicated by you as much as possible type of receipt.

We perform all necessary actions to ensure the fulfillment of your rights in accordance with the laws and regulations in force. In the event that you have objections related to the exercise of your rights, you have the right to apply to the UK supervisory authority.

We have the right not to fulfill the request under the following circumstances: 

• If it is not clearly worded; 
• If we cannot identify you as the Data Subject; 
• If the answer to such a request was already given; 
• If the amount of requested information is disproportionate; 
• If the request is unfounded (not attributable to us, and no explanations are provided as to why the request must be fulfilled); 
• If the laws and regulations stipulate that we are not entitled to provide such information or if we are obliged to store certain Personal Data.

The Company’s services do not address anyone under the age of 18 (hereinafter – Children). The Company does not knowingly collect personally identifiable information from anyone under the age of 18. If You are a parent or guardian and You are aware that Your Children has provided Company with Personal Data, please contact Us.

The Company assumes that, before using our Services, the Data Subject has read and accepted this Privacy Policy. If the Data Subject does not agree with this Privacy Policy, they are advised not to submit any information through our Services. The Company reserves the right to unilaterally modify and supplement the Privacy Policy. The Company will provide at least 30 days’ notice before the new Privacy Policy takes effect. Such notice will be provided via a notification on the Company’s Website.

If You, as the Data Subject, have any concerns about how we process Personal Data, please contact Us via e-mail: [email protected] or by sending a written application to Skanstes Street 25, Riga, LV-1013, Latvia.

If You, as the Data Subject, believe that we process personal data inappropriately, you have the right to submit a complaint to the Data State Inspectorate (Elijas Street 17, Riga, LV-1050, Latvia, e-mail: [email protected], phone: +371 6722313, website: www.dvi.gov.lv).