Welcome to TOTALLY HEALTHFUL LIMITED’s Privacy Notice.
TOTALLY HEALTHFUL LIMITED respects your privacy and is committed to protecting your personal data. This Privacy Notice 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.
We have taken great measures to ensure that your visit to our website is an excellent one and that your privacy is constantly respected. By visiting the TOTALLY HEALTHFUL LIMITED website, you are accepting the practices described in this policy.
1. Important information and who we are
Purpose of this Privacy Notice
This Privacy Notice aims to give you information on how TOTALLY HEALTHFUL LIMITED collects and processes your personal data through your use of this website, including any data you may provide through this website when you:- sign up to our newsletter, email us a question, purchase a product or take part in a competition.
This website is not intended for children and we do not knowingly collect data relating to children.
TOTALLY HEALTHFUL LIMITED is the controller and responsible for your personal data collectively referred to as “TOTALLY HEALTHFUL LIMITED”, “we”, “us” or “our” in this Privacy Notice).
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 the DPO using the details set out below.
Full name of legal entity: TOTALLY HEALTHFUL LIMITED
Name of DPO: Kay Johnson
Email Address: email@example.com
Postal Address: 12 Dalby Court, Gadbrook Business Centre, Northwich, Cheshire, CW9 7TN
Telephone number: 01565 740777.
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 (https://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 Notice and your duty to inform us of changes
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.
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 Notice of every website you visit.
2. What Personal data do we gather 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 personal data about you which we have grouped together below as follows:
- Identity Data such as first name, last name, marital status, username or similar identifier and title. You may be asked for your date of birth if you would like to receive loyalty points on your birthday or those of your pets.
- Contact Data such as billing address, delivery address, email address, PayPal email address, if different and contact telephone numbers (landline and mobile).
- Financial Data such as payment card details for order processing. (see section 5).
- Transaction Data such as details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data such as internet protocol (IP) address, your login data, browser type and version.
- Profile Data such as your username and password, purchases or orders made by you, your preferences, feedback and survey responses.
- Usage Data such as information about how you use our website, products and services.
- Marketing and Communications Data such as your preferences in receiving marketing from us and your communication preferences, social media messaging and / or posting.
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 our customers or suppliers (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 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.
How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions i.e. information you give us. We do not collect personal information about you except when you provide it to us. This information is used to fulfil orders, respond to your requests and communicating with you. 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:
- Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
- Technical Data from the following parties:
- apply for our products or services;
- create an account on our website or place a telephone order;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
a) analytics providers such as Google Analytics;
b) advertising networks such as Google, Bing, Twitter, Facebook, Instagram, Pintrest
c) search information providers such as Google, Bing, Yahoo
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Braintree, PayPal, Royal Mail, DPD, and Linnworks order management system.
- Identity and Contact Data from data brokers or aggregators such as PCA Predict, Healthful Pets Rewards, Reviews.co.uk, Zen Desk and Survey Monkey
- Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register
- Where you may have entered a partner competition and opted to receive emails from us as part of the entry process
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:
- 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.
You may visit the ICO (www.ico.org.uk) website to find out more about the types of lawful basis that we will rely on to process your personal data or contact us.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email. To help us make emails more productive and to improve service and your shopping experience, we sometimes send you newsletters of our services and products, notifications of changes to our policies, and order confirmations. If at any time, you do not want to receive emails from us, other than order notifications and receipts, please by clicking on the unsubscribe link at the bottom of the email.
Enquiries sent through forms generated by platforms such as Zen Desk, Facebook, Instagram and Twitter will be sent directly to a member of the team to answer.
We may personalise your shopping experience by using profile data to form a view on what we think may be most relevant to your needs or interests.
Purposes for which we will use your personal data
We have set out below in 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. We have also identified what our legitimate interests are where appropriate.
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. 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, please contact us.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||(a) Identity
|Performance of a contract with you|
|To process and deliver your order including:
(a) Manage payments, fees, delivery and charges
(b) Collect and recover money owed to us
(e)Marketing and Communications
(f) Products Ordered
|(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:
(b) Asking you to leave a review or take a survey
(d) 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/services)
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity
(e) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(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
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical
|Necessary for our legitimate interests (to define types of customers for our products and services, 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 goods or services that may be of interest to you||(a) Identity
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
You will receive marketing communications from us if you have requested information from us or have purchased goods or services from us or if you provided us with your details when you enter a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
You can stop us sending you marketing messages at any time by following the opt-out links on any marketing e-mail sent to you 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, where this information is required to be retained by relevant laws.
Do we share the information we receive?
We respect your privacy and appreciate your business. At no time do we ever provide your account contact or payment information to any third-party vendor, associate or service provider unless absolutely necessary in order to complete your transaction and order. However, we may share or transfer personal information and non-personally identifiable information with or to our affiliates, licenses and partners in order to:
- Enhance the website
- Enable them to undertake marketing activities on our behalf
Such third parties may not use your personal information for any other purposes and we require all third parties to respect the security of your personal data and to treat it in accordance with the law.
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 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.
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.
Your credit and debit card information is not stored anywhere within our database or website. Payment is made using secure third-party merchants including payment merchants such as Braintree and PayPal and they are responsible for your details and use high security connections SSL. If you do have any concerns or questions relating to credit and debit card details, then please contact the payment merchant or ourselves.
6. Data Retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfill 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. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us.
- Your Legal Rights
Under certain circumstances, you have rights under Data Protection laws in relation to your personal data. These rights include:
- 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 these rights set out above, please contact the Company’s DPO. Further information about these rights is available:https://ico.org.uk/for-the-public/personal-information/
No fee is 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. Occasionally it may take us longer than this time 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.