Our Privacy Promise
We take your privacy seriously and we respect your privacy and data protection rights. This privacy notice aims to give you information on how we collect and process your personal data through your use of our websites, and our services, including any data you may provide through our websites, our services when you sign up to receive news, complete a survey, provide feedback, or engage in service. Please take time to read this privacy notice in full, together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, to ensure that you understand and are happy with how we collect and process your personal data. This privacy notice supplements the other notices and is not intended to override them.
Changes to this Privacy Notice and Changes to Your Details
We will need to update this privacy notice from time to time as the law and/or our business changes and develops. We will endeavour to tell you in advance by sending a service message to you if we hold your email address. Otherwise, please look out for the flags on our websites and materials that indicates we have changed this privacy notice. If you continue to use our websites and/or services after we have changed our privacy notice, we will take this as an indication that you accept the changes. It is important that the personal data that we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third Party Links
Our websites, or the service we provide 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, or service, we encourage you to read the privacy notice of every website, plug-in and/or application that you visit. One such example is Google which can be found here https://privacy.google.com/businesses/compliance/
The Data We Process
Personal data 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 process different kinds of personal data about you, which we have categorised as follows:
- Identity Data:including your name, username (or similar unique identification numbers that we may apply to you), email address, marital status, title, date of birth and gender.
- Health Data:including any relevant history or current information about illnesses, conditions or information otherwise necessary to assist in providing our product or advice about our product
- Contact Data:including you billing address, delivery address, email address and telephone number(s).
- Technical Data:including information we collect through your use of our websites, where you came to our website from and where you went when you left our website, how often you visit and use our websites, technical information about the devices you use to access our websites and mobile apps (including your device’s unique identifying codes (e.g. its “MAC” address), relevant IP address, operating system and version, web browser and version, and geographic location).
- Usage Data: including information about how you use our website, products and services
- Marketing and Communications Data: including your preferences in receiving marketing from us and our third parties, your communication preferences and information on what you view, click on and access in and through our marketing emails, text messages and push notifications.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice. Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
We use different methods to collect personal data from and about you including through:
- Direct Interactions:you may give us your Identity, Contact, Profile and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email, social media or otherwise. This includes personal data you provide when you subscribe to our services, news, offers, promotions and updates or groups, request marketing to be sent to you, enter a competition or promotion, complete a survey or give us feedback.
- Social Media Interactions:our website and services may allow you to interact with them by using your social media applications. This interaction may result in us collecting some of your social media content (including posts and comments, pictures and video footage), but only where this content is in the public domain and/or where this content has been sent by you to us in a private message via social media; and also your Technical, Profile and Marketing and Communications Data.
- Other Third Parties or Publicly Available Sources:we may receive personal data about you from various third parties and public sources such as Google advertising containing technical data.
How we use your personal data
We only process your personal data when allowed to do so by law. Most commonly, we will process your personal data with your consent:
- Where we need to perform a contract, we are about to enter into, or have entered into, with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
The below table sets out how we process your personal data. Please contact us if you would like further information about the specific purpose for processing.
|1||To manage our relationship with you, which includes:|
communicating advice, instructions or care relating to our product or service,
to communicate with you about changes to our products, services, websites and mobile apps,
to gather feedback from you about our company, products, websites, mobile apps and other services and activities from time to time
to respond to, deal with and address any questions, suggestions, issues or complaints you have raised and reporting and analysis in respect of these,
to respond to any social media reviews, posts or other public comments you make about us, our company, products, websites, mobile apps, services or other activities
Marketing and Communications Data
Sensitive Data (only as required for dealing with feedback and complaints about specific issues)
Children’s Data (only as required for dealing with feedback and complaints for specific issues)
|Performance of a contract with you, such as providing advice on purchase, use and consumption of our product|
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|2||To provide information to legal and regulatory bodies where we are under a legal or regulatory obligation to do so.||Identity Data|
Marketing and Communications Data
|Necessary to comply with a legal obligation|
|3||To tailor our direct marketing to you and to send you direct marketing communications including via:|
Marketing and Communications Data
|In terms of tailoring our direct marketing, necessary for our legitimate interests, being to develop our business and inform our marketing strategy|
In terms of sending direct marketing where you are a customer and have not previously opted out of receiving such direct marketing, as necessary for our legitimate interests, being to offer you relevant products and services related to what we have previously provided to you
In terms of sending direct marking where you are not one of our customers, with your consent given when you sign up to our mobile app, website or otherwise give your details and provide consent when doing so
How we share your personal data
We cannot run our business or provide many of the services and benefits you expect to receive without involving other people and businesses. We only share your information in accordance with the laws applicable to us and for the purposes set out in the table in “How we use your personal data”.
We share your personal data with:
- Relevant employeesof our company who are all based in the EEA and US and who provide IT, HR, system administration, logistics, services and for whom you may have agreed can provide you with marketing communications.
- Service providers(mainly acting as processors, but sometimes as controllers) who help us provide our shipping logistics, websites, mobile apps, infrastructure and related services to you; for example, information technology companies who host our websites.
- Business partners(acting as controllers or processors) we may have over time; for example, if we enter into a joint venture, reorganisation, business merger or sale of part of our business, the other party may receive some or all of your information.
- Professional advisors(acting as controllers or processors); for example, our lawyers, insurers and insurance brokers, when they need it to provide advice to us or help us obtain insurance.
- Police, the Health and Safety Executive, local authorities, Her Majesty’s Revenue and Customs (HMRC), the Courts and any other central or local government bodies (acting as controllers or processors) where we are required to do so to comply with our legal obligations, or where they request it and we may lawfully disclose it, for example for the prevention and detection of crime or to report serious health and safety incidents.
- We also may share the information we collect with other third parties where we are legally obliged to do so; for example, to comply with a court order.
Some of our external third parties are based outside of the EEA so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data outside of the EEA, we ensure that a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use third parties based in the US, we may transfer personal data to them if they are part of the Privacy Shield which requires them to provide similar protection for personal data shared between the EEA and the US.
How We Keep Your Personal Data Secure
We take the security of your personal data very seriously and have in place appropriate security measures at all times, including where we share your information with our suppliers and partners, to protect your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have also put in place procedures 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.
Our Retention of Your Personal Data
We can only keep your personal data for as long as necessary for the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. The precise length of time we hold your personal data for varies depending on the individual circumstances, but in determining 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. We regularly review our retention periods to ensure that we are not keeping your data for longer than necessary. Details of retention periods for different aspects of your personal data are available by contacting us.
In certain circumstances, you may have the right to request access, transfer, rectification and/or erasure of the personal data that we process about you. You may also have the right to object to and/or restrict our processing of your personal data. Details of the rights are set out below.
- Human intervention:you may request human intervention where a decision has been made about you based solely on automated processing, and/or you may challenge that decision (this may happen in the context of our recruitment process where we collect information relating to whether or not a candidate has unspent criminal convictions).
- Access:you may request access to your personal data, which enables you to receive a copy of the personal data that we hold about you and to check to see if we are processing it lawfully.
- Transfer:you may request that we transfer your personal data to you or 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. Please 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.
- Rectification:you may request rectification 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
- Erasure:you may request erasure of the personal data that we hold about you. 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:you may object to how we are processing 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.
- Restriction:you may request that we restrict how we process 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.
- Withdrawal of Consent:where we have relied on your consent to process your personal data you will have the right to withdraw your consent at any time. 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.
To exercise any of these rights please contact us using the details in above. The ICO regulates most UK data and information laws. To learn more about your rights, visit the ICO website at www.ico.org.uk.