1. Introduction

Boba Box Europe B.V respects your privacy and is committed to protecting and personal data. 

This Privacy Policy is for

  • - Users of our website

  • - Individuals who receive our marketing communications

This Privacy Policy will inform you about how we look after your personal data, what your rights are and how the law protects you.

  1. Important information and who we are

Please read this Privacy Policy

It is important that you read this Privacy Policy and any other notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data.


Boba Box Europe B.V is the controller and responsible for your personal data (collectively referred to as “Boba Box”, “we” “us” “our” in this Policy).

If you have any questions about this Privacy Policy, please contact us using the details set out below.

Contact details

Full name of the legal entity:        Boba Box Europe B.V

Contact email address:        

Postal address:                                The Mark Offices, Fascinatio Boulevard 216-220, 3065 WB, Rotterdam, The Netherlands.

Telephone number:                        +44203 856 5880

Information Commissioner’s Office

You have the right to make a data protection complaint to the Information Commissioner’s Office (“ICO”), the UK’s supervisory authority (  We would, however, ask you to contact us in the first instance to deal with your concerns before you approach the ICO.

The ICO’s contact details are:

Online contact details:         

Postal address:                                Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

Telephone number:                        0303 123 1113

Changes to this Privacy Policy

This version was last updated on 22d September 2023

  1. The personal data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • - Identity Data includes [first name, last name, or similar identifier and title, and date of birth].

  • - Contact Data includes [email address, address and telephone number].

  • - Technical Data includes [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 this website].

  • - Profile Data includes [your password, experience ratings feedback and survey responses]. 

  • - Usage Data includes information about how you use our website, products and services.

  • - Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Information you give us

You may give us personal data when you fill in forms, correspond with us by post, phone, email or otherwise.  It includes personal data you provide when you register to use our site, subscribe to our service, search for a product, place an order, enter a competition, promotion or survey or when you report a problem or make a complaint.

Any financial and credit card information you use to purchase on our site is processed by SagePay.

Information we collect about you

Each time you visit our site we will automatically collect the following information:

  • - Technical information, including the Internet Protocol (IP) address used to connect your device to the Internet, your login information, browser type and version.

  • - Information about your visit, including the full Uniform Resource Locators (URL), products you viewed or searched for and any phone number used to call our customer service number.

Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Changes to your information

Please keep us informed if your personal data changes during your relationship with us.

  1. How we use your personal data

We will use your personal data when the law allows us to.  The table (below) sets out a description of the ways in which we use your personal data and the lawful basis or bases we rely on.


Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

(a) Identity

(b) Contact

Performance of a contract with you

To process and deliver your order including



(a) Identity

(b) Contact

((d) Transaction


Personal Data

(a) Performance of a contract with you

(b) Necessary for our legitimate interests.

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) 

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)


(a) Identity

(b) Contact


Necessary for our legitimate interests (to offer our products and services)


We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

  • Offers from us

We may use your personal data to form a view on what we think you may want or need or what may be of interest to you.

You will receive marketing communications from us if you have requested information from us and you may receive marketing communications from us if we are legally entitled to make unsolicited contact with you.  We will not contact from for marketing purposes if you have opted out of marketing.

  • Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

  • Opting out

You can ask us to stop sending you marketing messages at any time by following the opt-out links in any marketing message sent to you or by contacting us at any time.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  1. Disclosure of your personal data

We may share your personal data with the parties set out below for the purposes set out in section 5 above.

  • - External Third Parties as set out in section 10 below.

  • - Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

All third parties are required to respect the security of your personal data and to treat it in accordance with the law.

  1. International transfers

We do not transfer your personal data outside the United Kingdom/European Economic Area (EEA) other than as set out below.

Like most businesses we use software to support our operations. For example, we use Microsoft as our email providers. Your personal data may therefore be transferred out of the EEA because Microsoft and other major players in the software industry store some of their data in the U.S.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • - We will only transfer your personal data to countries that the ICO accepts provide an adequate level of protection of personal data.

  • - Where we use certain service providers, we may use specific contracts that the ICO accepts provide an adequate level of protection for the transfer of personal data.

  • - We may transfer personal data to organisations who have in place “binding corporate rules” i.e. organisations who have processes in place to protect personal data that have been given the seal of approval by the ICO or a data protection regulator approved by the ICO.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

  1. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 

We have put in place procedures and a data breach reporting policy to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  1. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our data retention policy which you can request by contacting us.

In some circumstances you can ask us to delete your data: see “request erasure” in section 10 below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

  1. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

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.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.



Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.


External Third Parties

  • - Service providers who provide IT and system delivery/administration services.

  • - Professional advisers who provide, for example, accountancy and legal services.

  • - Regulators and other authorities who may require reporting of processing activities in certain circumstances.

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