Updated August 4, 2019
1. Important Information and Who We Are
PURPOSE OF THIS POLICY
Email address: [email protected]
2. The 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:
(a) Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, and
(b) Contact Data includes billing address, delivery address, email address and telephone numbers, and
(c) Financial Data includes bank account and payment card details, and
(d) Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us, and
(e) 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, and
(f) Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses, and
(g) Usage Data includes information about how you use our website, products and services, and
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 offenses.
IF YOU FAIL TO PROVIDE PERSONAL DATA
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 goods 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.
3. Personal Data Collection Methods
We use different methods to collect data from and about you including
(a) Direct interactions, and
(b) Automated interactions, and
(c) third party sources.
You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
(a) apply for our products or services, and
(b) create an account on our website, and
(c) subscribe to our service or publications, and
(d) request marketing to be sent to you, and
(e) enter a competition, promotion or survey, and
(f) give us feedback or contact us.
As you interact with our website, we will automatically collect “Technical Data” about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. A “cookie” is a small data file that the Site transfers to your computer for storage to allow our server to “remember” certain information that identifies you as an individual. The Company may use Technical Data for general marketing purposes, to retain changes that you made, and to help enhance customer experience on the Site and you hereby consent to such use by the Company.
We will receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
(a) analytics providers such as Google and Facebook based inside or outside the US;
(b) advertising networks such as Facebook based inside or outside the US;
(c) search information providers such as Google and Facebook based inside or outside the US;
(d) Contact, Financial and Transaction Data from providers of technical, payment and delivery services;
(e) Identity and Contact Data from data brokers or aggregators based inside or outside the US; and
(f) Identity and Contact Data from publicly available sources inside or outside the US
4. How We Use Your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
(a) Where we need to perform the contract, we are about to enter into or have entered into with you, and
(b) 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, and
(c) Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience, or other transactions.
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.
5. Disclosures of Your Personal Data
We may share your personal data with the parties set out below;
(a) Internal Third Parties, including online marketers, and
(b) External Third Parties, including affiliates, and
(c) Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized 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 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.
7. Data Retention
We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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 unauthorized 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, regulatory, tax, accounting or other requirements.
For tax purposes, the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers. In some circumstances we will anonymize 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.