This Privacy Statement applies to our marketing activities as well as to the products and services that are sold by us from time to time.
We have tried to keep this Privacy Statement as simple as possible. If you have any questions after reading this document, please email us at firstname.lastname@example.org
WHAT IS PERSONAL INFORMATION AND WHAT DO WE COLLECT?
Personal information is information that does or may identify you.
You do not have to share your personal information with us, but if you choose not to, we may not be able to provide you with our products and services, or answer any questions that you may have.
We may collect your personal information from a variety of sources and this includes personal information that you provide to us directly.
This will include:
- The information you provide when you place an order and/or when you register with us, subscribe to receive our newsletter or information about our products, services, offers and promotions
- When you complete a survey or to enter one of our competitions
- Personal information contained within any enquiry you make
Some of the personal information we collect may be sensitive information. This might include information about your race or health. We will only collect this information with your explicit consent. Please see section below about sensitive information.
When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically collected information as “Device Information.”
We receive and store personal information automatically.
We collect Device Information using the following technologies:
“Log files” track actions occurring on the Site, and collect data including your IP address, device ID, location data, computer and connection information such as browser type and version, time zone setting, browser plug-in types and versions, operating systems and purchase history. Internet service provider, referring/exit pages, and date/time stamps.
“Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site and what pages you have visited. This helps us ensure that we deliver relevant content to you and to better understand what is of genuine interest to you. Please see more about profiling below.
PERSONAL INFORMATION FROM OTHER SOURCES
We collect personal data from other sources including trusted brand partners and where we operate an account on third-party platforms such as (but not limited to) Twitter, Facebook and Instagram.
Additionally, we receive information about you and other visitors’ interactions with our advertising to measure whether our advertising is relevant and successful.
WHEN WE COLLECT AND USE SENSITIVE INFORMATION
Sensitive information falls into a special category of personal information. This includes information relating to your health, race, sexuality or ethnicity.
We only collect sensitive information in limited circumstances which include:
- When you raise a specific enquiry through our customer services team
We may also collect sensitive data implicitly through your browsing or purchasing habits, or through you contacting us directly. For example, we may gain an indirect insight into wellbeing matters that are of clear interest to you.
We do not directly market to children. Our website is designed and intended for use by adults.
If we discover that we have collected personal data from a child without consent from a parent or guardian, we will delete that personal data as soon as practicable.
HOW WE USE YOUR PERSONAL INFORMATION
We only collect, process and disclose your personal information for specific and limited purposes. These include:
- To administer and fulfil any order you have placed with us;
- To screen orders for potential risk or fraud;
- To manage your subscription to our mailing list;
- To administer any competition that you may have entered;
- To send you our newsletter;
- To provide you with information about our products and offers that we believe will be of genuine interest to you;
- To direct you to content within our site that we think is relevant to you;
- To provide tailored product recommendations and targeted advertising based on what you have shared with us;
- To allow you to participate in any interactive features, survey or quizzes on our website;
- To answer any enquiry you may send to us;
- To authenticate that we are talking to the right person should we need to get in touch with you;
- To help us to understand and react to the changing interests and needs of our consumers so that we can improve our products and website.
We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).
Where required, we will obtain your consent to process your personal information. Where you have given consent, you may withdraw your consent at any time. Please see section below on withdrawing consent.
In some cases, we rely on legitimate interest for processing your personal information. A legitimate interest could exist, for example, where you have registered with us and we use the personal data collected to conduct data analytics to improve our products or services. Alternatively, we may rely on legitimate interest to assist us in fulfilling a contractual obligation. We will only rely on legitimate interest where there is no less intrusive way to process your personal data.
Profiling is an automated process that enables us to use your personal data to build a profile about you. This is one of the tools we use to analyse your online activities including surfing, searching and buying behaviour. We may also analyse your participation in surveys, email preferences and activity on social medial channels.
We use profiling to help us assess your likely preferences and interests. If you are registered on our mailing list, we may use profiling to select certain members so that we can send them a reward or a sample of a new product.
Profiling helps us only contact you about matters that we believe will be of genuine interest to you. You may withdraw your consent to prevent your personal information being used in this way by following the guidance set out at withdrawing consent below.
HOW WE SHARE YOUR PERSONAL INFORMATION
We do not sell your personal information to any third party.
We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Shopify to power our online store--you can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy. We also use Google Analytics to help us understand how our customers use the Site--you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
We share your personal information internally and with selected third parties in the following circumstances:
- To courier and logistics providers who deliver products you may have ordered, or to send samples or prizes;
- With payment processors who administer secure payment options.
- With parties who host and process personal information on our behalf in accordance always with applicable laws and regulations
When we are legally required to disclose it. This includes:
- To comply with a legal obligation;
- When we believe in good faith that an applicable law requires it;
- At the request of governmental authorities conducting an investigation;
- To verify or enforce any other policy relating to this website;
- To detect and protect against fraud, or any technical or security vulnerabilities;
- To respond to an emergency situation.
As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of targeted advertising by:
- FACEBOOK - https://www.facebook.com/settings/?tab=ads
- GOOGLE - https://www.google.com/settings/ads/anonymous
- BING - https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
The above list is not exhaustive and each web page you visit will have its own process to enable you to opt out of targeted advertising.
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.
“DO NOT TRACK”
Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.
HOW WE PROTECT YOUR PERSONAL DATA
We take the security of your personal information very seriously. This website is hosted by Shopify, one of the world’s largest online retail platforms, who also are the providers of the payment portal. We take every effort to protect your personal information from misuse, interference, loss, unauthorized access, modification or disclosure.
You can tell when the web page you’re using is secure as the letters 'https' will replace 'http' in the browser address window. You will also notice a padlock either next to your browser address window or at the bottom of your browser window.
HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?
We will keep your personal information for as long as we need it for the purpose it is being processed for. For example, where you have purchased one of our products online, we will keep your personal information related to the purchase so we can perform the specific contract you have entered. After which, we will keep the personal information for a period which enables us to handle or respond to any complaints, queries or concerns relating to the purchase.
Your personal information may also be retained so that we can continue to improve your experience with us and to ensure that you can enjoy your subscription to our mailing list and any newsletters.
We will actively review the personal information we hold and delete it securely, or in some cases pseudonymise or anonymise it, when there is no longer a legal, business or consumer need for it to be retained.
YOUR RIGHTS AS A DATA SUBJECT
This is a summary of your rights relating to the personal information we hold about you.
The right to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your personal information and your rights. Therefore, we are providing you with the information in this statement.
The right to access and rectification. You have the right to access, correct or update your personal information at any time. We understand the importance of this and should you want to exercise your rights, please contact us as by emailing email@example.com;
The right to data portability. The personal information you have provided us with is portable. This means it can be moved, copied or transmitted electronically under certain circumstances.
The right to be forgotten. Under certain circumstances, you have the right to request that we delete your personal information. If you wish to delete the personal information we hold about you, please let us know and we will take reasonable steps to respond to your request in accordance with legal requirements. If the personal data we collect is no longer needed for any purposes and we are not required by law to retain it, we will do what we can to delete, destroy or permanently de-identify it. We cannot remove your orders, items purchased and values as we may require these for historical accounting, but your personal affiliation with these orders will be anonymised and all of your personal information would no longer be held by us if you want to exercise your right to be forgotten.
The right to restrict processing. Under certain circumstances, you have the right to object to certain types of processing, including processing for direct marketing (i.e. receiving emails from us about our products).
The right to lodge a complaint with a supervisory authority. You have the right to lodge a complaint directly with any local Supervisory Authority about how we process our personal information;
The right to withdraw consent. If you have given your consent to anything we do with your personal information, you have the right to withdraw your consent at any time by contacting us using the details below.
Rights related to automated decision-making. You have the right not to be subject to any decision which is based solely on automated processing in certain circumstances.
If you wish to contact us about your personal information, including where you wish to withdraw consent or restrict certain processing activities, please email us at firstname.lastname@example.org or by mail using the details provided below:
Hot Elephant Ltd, Ashcombe Court, Woolsack Way, Godalming, Surrey, GU7 1LQ, United Kingdom
We shall update this privacy statement from time to time to reflect for example, customer feedback and changes to our products/services or for other operational, legal or regulatory reasons.
Date: December 2018