Privacy Policy

PRIVACY POLICY – HEIDI ROSE LIMITED

INTRODUCTION  

We respect your privacy and are committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

  1. IMPORTANT INFORMATION AND WHO WE ARE

    PURPOSE OF THIS PRIVACY POLICY

    This Privacy Policy aims to give you information on how Heidi Rose Limited collects and processes your personal data through your use of this website and your interactions with us, including any data you may provide through this website when you sign up to our newsletter, sign up for our free or paid services or offerings, or take part in a competition.

    It is important that you read this Privacy Policy together with any other privacy policy or notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other policies or notices and is not intended to override them.

    CONTROLLER  

    Heidi Rose Limited is the controller and responsible for your personal data (collectively referred to as “Heidi Rose Limited”, “we”, “us” or “our” in this Privacy Policy).

    We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

    CONTACT DETAILS  

    Our contact details are set out in table 1 below:

    Table 1

    Full name of legal entity

    Heidi Rose Limited

    Name of data privacy manager

    Quinten de Graaf

    Email address

    Quinten@heidi-rose.com

    Postal address

    Suite 1

    5th Floor

    City Reach

    5 Greenwich View Place

    London

    E14 9NN

    United Kingdom

     

    You have the right to make a complaint at any time to the Information Commissioner’s Office (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.

    CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES  

    This version was last updated in May 2021.

    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  

     This website 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, we encourage you to read the privacy policy of every website you visit.

    1. 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 in table 2 below:

    Table 2

    Identity Data

    includes first name, last name, username or similar identifier, title, date of birth and gender

    Contact Data

    includes billing address, delivery address, email address and telephone numbers

    Financial Data

    includes payment card details

    Transaction Data

    includes details about payments to and from you and other details of products and services you have purchased from us

    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 on the devices you use to access this website

    Profile Data

    includes purchases or orders made by you, feedback and survey responses

    Usage Data

    includes information about how you use our website, products and services

    Marketing and Communications Data

    includes your preferences in receiving marketing from us and our third parties and your communication preferences

     

    We may collect, use, store and transfer different kinds of personal data from you about the children or young people you are purchasing goods for, which we have grouped together in table 3 below:

    Table 3

    Child’s Identity Data

    includes first name, last name, date of birth, gender and age

    Child’s Contact Data

    includes residential address, email address and telephone numbers

    Child’s Transaction Data

     

    includes details of products the child has purchased or accessed 

    Child’s Profile Data

    includes feedback

    Child’s Marketing and Communications Data

    includes the child’s preferences in receiving marketing from us and our third parties and the child’s communication preferences

     

    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 Policy.

     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 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.

    1. HOW IS YOUR PERSONAL DATA COLLECTED?

    We use different methods to collect data from and about you, as set out in table 4 below:

    Table 4

    Direct interactions

    You may give us your Identity, Contact, Financial, Transaction, Profile and Marketing and Communications Data, as well as the relevant Child’s Identity, Child’s Contact, Child’s Transaction, Child’s Profile and Child’s Marketing and Communications 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;

    •      sign up for free services or offerings;

    •      create an account on our website;

    •      subscribe to our service or publications;

    •      request marketing to be sent to you;

    •      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. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.

    Third parties or publicly available sources.

    We may receive personal data about you from various third parties as set out below:

    •      Technical Data from analytics providers such as Google;

    •      Contact, Financial and Transaction Data from providers of technical, payment and delivery services PayPal and Slack.

     

    1. 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 

    • where you have consented for us to do so;
    • 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.

    See table 5 below 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 table 5 descriptions of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

    Please 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 via email at info@heidi-rose.com or via the Contact page on our website 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 table 5 below:

    Table 5

     

    Purpose/Activity

     

    Type of data

     

    Lawful basis for processing including basis of legitimate interest

    To register you as a new customer.

     

    (a) Identity

    (b) Contact

    (c) Child’s Identity

    (d) Child’s Contacty

    Performance of a contract with you.

    To provide our free or paid offerings.

     

    (a) Identity

    (b) Contact

    (c) Transaction

    (d) Profile

    (e) Usage

    (f) Marketing and Communications

    (g) Child’s Identity

    (h) Child’s Contact

    (i) Child’s Transaction

    (j) Child’s Profile

    (k) Child’s Marketing and Communications 

    (a) Performance of a contract with you.

    (b) Necessary for our legitimate interests (to study how customers use our products, to develop them, to grow our business and to inform our marketing strategy).

    To process and deliver your order including:

    (a) manage payments, fees and charges;

    (b) collect and recover money owed to us.

     

    (a) Identity

    (b) Contact

    (c) Financial

    (d) Transaction

    (e) Marketing and Communications

    (f) Child’s Identity

    (g) Child’s Contact

    (h) Child’s Transaction

    (i) Child’s Marketing and Communications

    (a) Performance of a contract with you.

    (b) Necessary for our legitimate interests (to recover debts due to us).

     

    To manage our relationship with you which will include:

    (a) notifying you about changes to our Terms or Privacy Policy;

    (b) asking you to leave a review or take a survey.

     

    (a) Identity

    (b) Contact

    (c) Profile

    (d) Marketing and Communications

    (e) Child’s Identity

    (f) Child’s Contact

    (g) Child’s Profile

    (h) Child’s Marketing and Communications 

    (a) Performance of a contract with you.

    (b) Necessary to comply with a legal obligation.

    (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products).

     

    To enable you to partake in a prize draw, competition or complete a survey.

     

    (a) Identity

    (b) Contact

    (c) Profile

    (d) Usage

    (e) Marketing and Communications

    (f) Child’s Identity

    (g) Child’s Contact

    (h) Child’s Transaction

    (i) Child’s Profile

    (j) Child’s Marketing and Communications

    (a) Performance of a contract with you.

    (b) Necessary for our legitimate interests (to study how customers use our products, to develop them and grow our business).

     

    To administer and protect our business and this website (including troubleshooting, data analysis, fraud risk analysis, testing, system maintenance, support, reporting and hosting of data).

    (a) Identity

    (b) Contact

    (c) Technical

    (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, and to prevent fraud).

    (b) Necessary to comply with a legal obligation.

    To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.

     

    (a) Identity

    (b) Contact

    (c) Profile

    (d) Usage

    (e) Marketing and Communications

    (f) Technical

    Necessary for our legitimate interests (to study how customers use our products, to develop them, to grow our business and to inform our marketing strategy).

    To use data analytics to improve our website, products, marketing, customer relationships and experiences.

     

    (a) Technical

    (b) Usage

    Necessary for our legitimate interests (to define types of customers for our products, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).

    To make suggestions and recommendations to you about products that may be of interest to you.

     

    (a) Identity

    (b) Contact

    (c) Technical

    (d) Usage

    (e) Profile

    (f) Child’s Identity

    (g) Child’s Contact

    (h) Child’s Profile 

    Necessary for our legitimate interests (to develop our products and grow our business).

     

    MARKETING  

    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, as well as the relevant Child’s Identity, Child’s Contact, and Child’s 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 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 products or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

    THIRD-PARTY MARKETING  

    We will get your express opt-in consent before we share your personal data with any company for marketing purposes.

    OPTING OUT  

    You can ask us or third parties to stop sending you marketing messages at any time by:

    • by following the opt-out or “unsubscribe” links on any marketing message sent to you; or
    • by contacting us via email at info@heidi-rose.com or via the Contact page on our website 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, warranty registration, product/service experience or other transactions.

    COOKIES  

    You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy, which is available 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 via email at info@heidi-rose.com or via the Contact page on our website.

    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.

    1. DISCLOSURES OF YOUR PERSONAL DATA

    We may have to share your personal data with the parties set out in table 6 below for the purposes set out in the table in paragraph 4 above.

    Table 6

     

    Third Party

    Purpose of disclosure

    Link to Third Party Privacy Policy

    Klaviyo

     

    To manage email marketing and communications with customers

    https://www.klaviyo.com/privacy/policy

     

    We may also share your personal data with service providers who we engage to work with our business, including but not limited to those providing IT support, administrative support, and professional advice such as legal and financial advisers.

    We may also share your personal data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

    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.

    1. INTERNATIONAL TRANSFERS

    It is sometimes necessary for us to share your personal data outside of the UK. Under data protection law, we can only transfer your personal data to a country or international organisation outside of the UK where: 

    • the UK government or, where the EU GDPR applies, the European Commission, has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an ‘adequacy decision’);
    • there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
    • a specific exception applies under data protection law.

    Please contact us via email at info@heidi-rose.com or via the Contact page on our website if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

    1. 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.

    1. DATA RETENTION

    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.

    By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six (6) years after they cease being customers for tax purposes.

    In some circumstances you can ask us to delete your data: see clause 9.3 below regarding Request erasure below for further information.

    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.

    1. YOUR LEGAL RIGHTS

    Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:

    9.1.   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.

    9.2.   Request correction of your 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.

    9.3.   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 clause 9.4 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.

    9.4.   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.

    9.5.   Request restriction of processing 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.

    9.6.   Request 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. 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.

    9.7.   Right to 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.

    If you wish to exercise any of the rights set out above, please contact us via email at info@heidi-rose.com or via the Contact page on our website.

    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 may 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 from receiving the request from you. Occasionally it may 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 on expected timeframes.