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Purpose of this Privacy Notice
This privacy notice aims to give you information on how Splush.co collects and processes your personal data through your use of this website, including any data you may provide through this website when you shop with us. Whitecrest Ventures Limited is the data controller and is responsible for your personal data (collectively referred to as "Splush", "we", "us" or "our" in this privacy notice). 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.
How We Use Your Personal Data
We will only use your personal data when the law allows us to, and only for the purposes agreed to when you provided it. 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.
• Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to 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 at email@example.com, updating your preferences on your "My Account" section of the website, by 'opting out' of marketing communications in any marketing e-mail sent to you or by following the instructions in any SMS we send.
Purpose for Which We Will Use Your Personal Data
We will use your personal data to:
• Register you as a new customer
• Process and deliver your order(s) including
• Managing payments, fees and charges
• Collecting and recovering money owed to us
• To manage our relationship with you which will include:
• Asking you to leave a review or take a survey**
• To enable you to partake in a prize draw, competition or complete a survey**
• 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/services, marketing, customer relationships and experiences
• To make suggestions and recommendations to you about goods or services that may be of interest to you**
• Verify your age when you purchase a product with age restrictions associated to it e.g. alcohol. In order to do this, your data will be shared with relevant credit agencies.
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 personal information by filling in forms or by corresponding with us by post, phone, e-mail or otherwise. This includes information you provide when you:
• purchase any of our products or services;
• create an account on our website;
• subscribe to our newsletters or other publications;
• enter a competition, promotion or survey; or
• give us some feedback.
• Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
Your Legal Rights
You have the right to:
• Request what personal data we hold about you;
• Request any corrections to the personal data that we hold about you;
• Request erasure of your personal data;
• 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;
• Request restriction of processing of your personal data;
• Request the transfer of your personal data to you or to a third party; or
• Withdraw consent at any time where we are relying on consent to process your personal data.
•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 may refuse to comply with your request in these circumstances.
•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.
•We try to respond to all legitimate requests within one month. If your request is particularly complex, or you have made a number of requests, it may take us slightly longer (up to an additional month). In this case, we will notify you within one month of the request being made with the estimated response time and the reason for the delay, and will keep you updated.
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). When you complete an online form, register or shop with us online, we may collect, use and store different kinds of personal data about you such as your name, gender, date of birth, billing/delivery address, e-mail address and telephone number. We may also collect and retain information about your interactions with us either online or through our contact centres so that we can process your transactions and deal with any future queries.
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.
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.
•In certain situations, we can collect and process your data with your consent.
•In limited situations, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.
•When collecting your personal data, we'll always make clear to you which data is necessary in connection with a particular contractual or legal requirement.
•We may process your personal data without your knowledge or consent (for example, in relation to fraud management or to assist with investigations by the police or other regulatory bodies) in compliance with the above rules, where this is required or permitted by law.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at firstname.lastname@example.org, updating your preferences on your "My Account" section of the website, by 'opting out' of marketing communications in any marketing e-mail sent to you or by following the instructions in any SMS we send.
Promotion 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 strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may send you marketing about our own goods and services if either you have opted in to receive our marketing messages, or you have previously bought or enquired about similar goods or services from us and you have not opted out from receiving our marketing messages. You can, should you wish, unsubscribe to any or all our marketing material at any time. You can unsubscribe at any time by clicking the 'unsubscribe' link in any marketing email we send, updating your "My Account" section on our website or using our preference centre. You can also contact us at any point to opt out of any or all marketing communications.
Third Party Marketing
We will get your express opt-in consent before we share your personal data with any company outside Splush.co for marketing purposes.
Third Party Links
Clicking on links to third-party websites, plug-ins and applications contained within this website, 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, we encourage you to read the privacy notice of every website you visit.
Disclosures Of Your Personal Data:
We may have to share your personal data with the parties set out below for the purposes set out above (in 'Purposes for which we will use your Personal Data'):
• To allow a third party order processor to contact you by email about processing your order.
• Third party suppliers in order to fulfil orders placed by you; or
• We may, from time to time, expand, sell or reduce Splush.co and this may involve the transfer of divisions or the whole business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owner or controlling party, under the terms of this Privacy Notice.
• Marketing companies to show you products, special offers or services, from Splush.co that might interest you while you're browsing the internet.
• Data insight companies to ensure your details are up to date and accurate. 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.
We have appropriate security measures in place 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 procedures in place 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.
How Long Will You Use My Personal Data For?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 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 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.
In some circumstances we may anonymise 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.
If You Fail To Provide Your 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.
Data Protection Office
We have appointed a Data Protection Officer ("DPO") who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact Data Protection Officer, Whitecrest Ventures Limited, Essex House, Sterling Industrial Estate, Rainham Road South, Dagenham RM10 8TX or e-mail email@example.com
Contacting The Regulator
If you feel that your data has not been handled correctly, or you wish to make a complaint, you have the right to contact the Information Commissioner's Office ("ICO"), the UK supervisory authority for data protection issues, at any time. You can contact them by telephone (0303 123 1113) or via their website (http://www.ico.org.uk/concerns). We would, however, be grateful for the chance to deal with your concerns before you approach the ICO so would please ask you to contact us in the first instance.