1. Important information and who we are
This website is not intended for children and we do not knowingly collect data relating to children.
Email address: firstname.lastname@example.org
Postal address: 48 Warwick Street, London, W1B 5AW
You have the right to make a complaint at any time to the Information Commissioner’s Office (the ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
It is important that the personal data 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
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:
- Contact Data includes billing address, delivery address, email address and telephone number(s);
- Identity Data includes first name, last name, username or similar identifier and title;
- Marketing & Communications Data includes your preferences in receiving marketing from us and other members of our corporate group and your communication preferences;
- Profile Data includes your username and password, purchases/orders made by you and your preferences and feedback;
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, marketing emails read and links within them followed, operating system and platform and other technology on the devices you use to access our website;
- Transaction Data includes details about payments to and from you and other details of products you have purchased from us (as well as details relating to their delivery/return);
- Usage Data includes information about how you use our website.
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.
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 that you have ordered). In this case, we may have to cancel an order that you have placed but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- direct interactions. You may give us your Identity, Contact, Marketing & Communications and Profile Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- purchase our products;
- create an account on our website;
- request marketing to be sent to you; or
- give us feedback or contact us;
- third parties. We will receive personal data about you from various third parties as set out below:
- Technical Data from the following parties:
- analytics providers such as Google;
- advertising networks/providers such as Google Ads, Instagram and Pinterest; and
- mailing list service providers such as The Rocket Science Group LLC t/a ‘Mailchimp’ (incorporated and registered in Georgia, USA and whose address is at 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308) (Mailchimp);
- Transaction Data from providers of payment and delivery services such as:
- Stripe Payments Europe, Limited (incorporated and registered in the Republic of Ireland with company number 513174 and whose registered office is at c/o A&L Goodbody, IFSC, North Wall Quay, Dublin 1) (Stripe); and
- UPS UK Ltd (incorporated and registered in England and Wales with company number 01852013 and whose registered office is at UPS House, Forest Road, Feltham, Middlesex, TW13 7DY) (UPS).
- Technical Data from the following parties:
4. How we use your personal data
We will only use your personal data when permitted by law. Most commonly, we will use your personal data in the following circumstances:
- where we need to perform the 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; and
- where we need to comply with a legal obligation;
- where you consent.
Click to find out more about the types of lawful basis that we will rely on to process your personal data.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data and which of the legal bases we rely on to do so. Where relevant, we have also identified our legitimate interests.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/activity||Type of data||Lawful basis for processing (including, where applicable, the relevant legitimate interest)|
|To register you as a new customer||
|To process and deliver your order, including: (a) managing payments, fees and charges (which includes sharing your personal data with [Stripe] and [UPS] for payment processing and delivery); and (b) collecting and recovering money owed to us||
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||
|To use data analytics to improve our website, products, marketing, customer relationships and experiences, including creating aggregated data for these purposes||
|To make suggestions and recommendations to you about goods that may be of interest to you||
|To share your details with members of our corporate group so that they can provide you with information about their products and services||
Marketing from us
You will only receive marketing communications from us if you have requested to receive this information from us (and have not later opted out).
Marketing from other members of our corporate group
We will not otherwise share your personal data with third parties for marketing purposes.
At any time, you can request that we stop sending you marketing messages by following the opt-out links on any marketing message sent to you or by contacting us at email@example.com.
For information about the cookies we use, please click here.
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 for the purposes set out in the table above:
- internal third parties as set out in the Glossary;
- external third parties as set out in the Glossary; and
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. International transfers
Mailchimp is based outside European Economic Area (the EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
We ensure a similar degree of protection is afforded to your personal data by using specific contracts approved by the European Commission which give personal data the same protection it has in the EEA. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Please contact us if you want further information about this mechanism used by us for transferring your personal data out of the EEA.
7. 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 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.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil 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 unauthorised use or disclosure of the personal data;
- the purposes for which we process the personal data and whether we can achieve those purposes through other means; and
- applicable legal, regulatory, tax, accounting and/or other requirements.
We will delete all personal data that we hold about you where we have not had any contact from or with you during a clear three-year period.
In some circumstances, you can ask us to delete your data – see your legal rights below for further information.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights.
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw 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 could 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 could 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.
Compliance with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation to which we are subject.
Consent means processing your personal data where you have freely opted into us using it for a specific purpose.
Legitimate interest means processing your personal data to pursue a particular legitimate interest (whether ours or a third party/ies’). 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 legitimate interests. We do not use your personal data for activities where the legitimate 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 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.
Internal Third Parties
- Alix Lawson Ltd (incorporated and registered in England & Wales with company number 11396464 and whose registered office is at 48 Warwick Street, London, W1B 5AW) where you have consented to receive marketing from our other corporate group members.
External Third Parties
- Stripe, which provides payment processing services.
- Krystal Hosting Ltd (incorporated and registered in England and Wales with company number 07571790 and whose registered office is at Kemp House, 152 – 160 City Road, London, EC1V 2NX) which provides website hosting and data back-up services.
- Mailchimp, which provides mailing list services.
- JAB Anstoetz Group, which provides goods.
- UPS, which provides delivery services.
YOUR LEGAL RIGHTS
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:
- if you want us to establish the data’s accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- 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;
- 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.