This privacy policy explains how Empire Kitchen (operated by Lace Flowers) collects, uses, stores, and protects personal data when you visit our website, book a workshop, or subscribe to our membership.
Empire Kitchen is an internationally operating business. This policy is built on internationally recognised data protection principles, including those set out in the General Data Protection Regulation (GDPR) as an international benchmark, and is designed to meet the reasonable expectations of individuals in any country. We are committed to handling your data transparently, responsibly, and with respect for your rights regardless of where you are located.
1. Who We Are
1.1 Empire Kitchen is operated by Lace Flowers, an internationally operating sole trader registered in the Republic of Paraguay.
1.2 For the purposes of this policy, Lace Flowers is the data controller — the person responsible for deciding how and why your personal data is collected and used.
1.3 You can contact us about any privacy matter at: hello@empire.kitchen
1.4 This policy applies to all personal data collected through empire.kitchen, our workshop booking processes, our membership platform, and any communications with us.
2. What Personal Data We Collect
2.1 We collect the following categories of personal data depending on how you interact with us:
Data we collect
Why we collect it
Legal basis
Name and email address
To process bookings, deliver membership access, and send relevant communications
Contract / Legitimate interest
Company name
To administer business and team membership accounts
Contract / Legitimate interest
Team size (approximate)
To assign the correct membership tier and manage quarterly tier reviews
Contract
Tax number (business clients)
To comply with invoicing and financial record-keeping requirements
Legal obligation
Payment transaction records
To maintain financial records and resolve payment queries. Card details are processed by Stripe and are not stored by Empire Kitchen.
Contract / Legal obligation
Membership account details
To manage your access to the membership platform including login email and subscription status
Contract
Communication preferences
To manage your newsletter subscription and opt-in status
Consent
Website usage data
To understand how visitors use our website and improve the user experience. See section 7.
Legitimate interest
2.2 We do not collect sensitive personal data such as health information, ethnic origin, religious beliefs, or biometric data through our standard services.
2.3 We do not knowingly collect personal data from children under the age of 18. Our services are intended for adults only.
3. How We Collect Your Data
3.1 We collect data directly from you when you book a workshop, subscribe to the membership, sign up to our newsletter, or contact us by email.
3.2 We may also collect limited technical data automatically when you visit our website. See section 7 for details.
3.3 We do not purchase data from third parties or obtain your personal data from any source other than your direct interaction with us.
4. How We Use Your Data
4.1 We use your personal data only for the purposes for which it was collected, including: processing and confirming bookings, setting up and managing membership accounts, sending booking confirmations and membership communications, managing quarterly tier reviews for team memberships, issuing invoices and maintaining financial records, sending our newsletter where you have opted in, responding to enquiries, and complying with our legal and financial obligations.
4.2 We will not use your data for automated decision-making or profiling.
4.3 We will not sell your personal data to any third party under any circumstances.
4.4 We will not use your data for any purpose materially different from those described in this policy without notifying you and, where required, obtaining your consent.
5. Legal Basis for Processing
5.1 We process your personal data on the following internationally recognised legal bases:
Legal basis
When it applies
Contract
Processing necessary to fulfil your workshop booking or membership subscription, or to take steps before entering into an agreement with you
Legal obligation
Processing required to comply with invoicing, tax, or other applicable legal requirements
Legitimate interests
Processing necessary for our reasonable business interests — such as account administration, website improvement, and communicating with business clients — where these interests are not overridden by your rights and freedoms
Consent
Processing for marketing and newsletter communications where you have actively opted in. You may withdraw consent at any time by unsubscribing or contacting us.
6. Data Storage and Third-Party Processors
6.1 Your personal data is stored and processed within Systeme.io, our business operations and membership platform. Systeme.io is a French company operating within the European Union and subject to GDPR. As an EU-based processor, Systeme.io maintains recognised international data protection standards.
6.2 Payment transactions are processed by Systeme.io's integrated payment processor. Empire Kitchen does not store, access, or retain card payment details.
6.3 Newsletter and membership communications are sent via Systeme.io's email platform. You can unsubscribe from marketing emails at any time using the unsubscribe link in any email, or by contacting hello@empire.kitchen.
6.4 We do not share your personal data with any other third parties except where required by applicable law or where you have given explicit consent.
6.5 Where data is transferred internationally, we ensure that appropriate safeguards are in place consistent with internationally recognised data protection standards.
7. Website Analytics
7.1 Empire Kitchen uses Fathom Analytics to understand how visitors use our website. Fathom Analytics is a privacy-respecting analytics tool that does not use cookies, does not track individuals across websites, and does not collect personally identifiable information.
7.2 Fathom Analytics is designed to be compliant with major international privacy regulations including GDPR, CCPA, and PECR. No cookie consent banner is required as no personal data is collected.
7.3 Fathom Analytics is not yet active on empire.kitchen. This policy will be updated to confirm activation when it is in use. No other analytics or tracking tools are currently active on our website.
7.4 We do not use advertising pixels, social media tracking tools, or behavioural retargeting technology on our website.
8. Cookies
8.1 Our website uses only essential technical cookies necessary for the website and checkout process to function. We do not use tracking, advertising, or analytical cookies.
8.2 When Fathom Analytics is activated it will not introduce any cookies. Our cookie use will remain limited to essential functional cookies only.
9. How Long We Keep Your Data
9.1 We retain personal data only for as long as is necessary for the purpose for which it was collected, or as required by applicable law or good financial practice.
Type of data
Retention period
Workshop booking records
6 years from the date of booking — consistent with standard financial record-keeping practice
Membership account data
Duration of active subscription, plus 6 years after the subscription ends
Invoice and payment records (including tax numbers)
6 years from the date of issue — consistent with standard financial and tax record-keeping practice
Newsletter subscribers
Until you unsubscribe or request deletion
Enquiry and support emails
2 years from the date of last communication, unless part of a booking record
Website analytics
Aggregated and anonymised only — no personal data retained by Fathom Analytics
10. Your Rights
10.1 Regardless of where you are located, Empire Kitchen recognises and respects the following internationally established data subject rights:
Your right
What it means
Access
You may request a copy of the personal data we hold about you at any time.
Rectification
You may ask us to correct any inaccurate or incomplete personal data we hold about you.
Erasure
You may ask us to delete your personal data where there is no longer a lawful reason for us to hold it. This right does not apply where we are required to retain data for financial or legal purposes.
Restriction
You may ask us to restrict how we process your data in certain circumstances.
Portability
Where we process your data by automated means on the basis of consent or contract, you may request that data in a structured, commonly used, machine-readable format.
Object
You may object to processing based on legitimate interests. You have an absolute right to object to processing for direct marketing purposes at any time.
Withdraw consent
Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
10.2 To exercise any of these rights, please contact us at hello@empire.kitchen with the subject line 'Data Request'. We will respond within 30 days. We may need to verify your identity before processing your request.
10.3 If you believe we have not handled your data correctly and we have been unable to resolve your concern, you have the right to complain to the relevant data protection authority in your country of residence.
11. Data Security
11.1 We take reasonable and appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, disclosure, or misuse.
11.2 All personal data is stored within Systeme.io's or Stripe's platform, which maintains its own security standards and data protection obligations as a processor.
11.3 Access to membership accounts is protected by password. It is your responsibility to keep your credentials secure. For team memberships, the organisation is responsible for the security of the shared account credentials.
11.4 In the event of a data breach that poses a risk to individuals, we will notify affected individuals promptly and take appropriate remedial action.
12. Business Clients
12.1 When you purchase a workshop or team membership on behalf of your organisation, we collect data relating to your business including company name, approximate team size, and tax number. This data is used solely to administer your account and meet our financial obligations.
12.2 Empire Kitchen does not collect personal data about individual employees within your organisation. The shared team login and any associated account activity are the organisation's responsibility to manage.
12.3 If an employee contacts us directly, we will handle their personal data in accordance with this privacy policy.
13. International Visitors and Clients
13.1 Empire Kitchen serves clients in multiple countries including the United Kingdom, the United States, and internationally. This policy is designed to meet the reasonable data protection expectations of individuals in all jurisdictions we serve.
13.2 If you are located in the European Union or United Kingdom, you may have additional rights under GDPR or UK GDPR respectively. We recognise and honour those rights as set out in section 10.
13.3 If you are located in California or another US state with specific privacy legislation, we recognise your rights under applicable law including the right to know what data we collect, the right to deletion, and the right to opt out of sale of personal information. We do not sell personal data.
13.4 If your jurisdiction has specific data protection requirements not addressed in this policy, please contact us at hello@empire.kitchen and we will address your request in accordance with applicable law.
14. Children
14.1 Empire Kitchen's services are intended for adults aged 18 and over. We do not knowingly collect personal data from children under 18. If you believe a child has provided us with personal data, please contact us at hello@empire.kitchen and we will delete it promptly.
15. Changes to This Policy
15.1 We may update this privacy policy from time to time to reflect changes in our practices, our services, or applicable standards. The current version will always be available at empire.kitchen/privacy with the effective date clearly noted.
15.2 We will notify active members and recent clients of material changes by email where reasonably practicable.
16. Contact Us
16.1 If you have any questions about this privacy policy or how we handle your data, or if you wish to exercise any of your rights, please contact us:
Empire Kitchen · Operated by Lace Flowers
hello@empire.kitchen · empire.kitchen
For data requests, please use the subject line: Data Request
We will respond within 30 days.