What this policy covers
The data controller is Nellben Ltd (referred to in this policy as “we” or “us”).
We are committed to doing the right thing when it comes to how we collect, use and protect your personal data. That’s why we’ve developed this privacy and cookies policy (“Policy”), which:
sets out the types of personal data that we collect
explains how and why we collect and use your personal data
explains when and why we will share personal data within our organisation and our partners
explains the rights and choices you have when it comes to your personal data
We offer a wide range of products and services, so we want you to be clear about what this Policy covers. This Policy applies to you if you use our services (referred to in this Policy as “our Services”). Using our Services means:
This Policy applies if you contact us or we contact you about our Services
Personal data we collect
This section tells you what personal data we may collect from you when you use our Services and what other personal data we may receive from other sources.
When you browse our Website, we may collect:
Information about your online browsing behaviour on our Website and information about when you click on one of our adverts (including those shown on other organisations’ websites via Facebook or Gooogle advertising)
Information about any devices you have used to access our Services (including the make, model and operating system, IP address, browser type and mobile device identifiers)
When you contact us or we contact you regarding our Services, we may collect:
Personal data you provide about yourself anytime you contact us about our Services (for example, your name, username and contact details), including by phone, email or post or when you speak with us through social media
Details of the emails and other digital communications we send to you that you open, including any links in them that you click on
Other sources of personal data
We may also use personal data from other sources, such as specialist companies that supply information, online media channels, our Retail Partners and public registers. For example, this other personal data helps us to:
review and improve the accuracy of the data we hold; and
improve and measure the effectiveness of our marketing communications, including online advertising.
How and why we use personal data
This section explains in detail how and why we use personal data. We use personal data to:
Make our Services available to you
This means that processing your personal data allows us to:
Discuss services we offer with you.
Why do we process your personal data in this way?
We need to process your personal data so that we can provide you with the goods and services you want to buy and help you with any orders and refunds you may ask for.
Contact and interact with you
Contact you about our Services, for example by phone, email or post or by responding to social media posts that you have directed at us.
Why do we process your personal data in this way?
We want to serve you better as a customer so we use personal data to provide clarification or assistance in response to your communications.
Sharing personal data with other organisations
This section explains how and why we share personal data with other organisations.
We may share personal data with other organisations in the following circumstances:
if the law or a public authority says we must share the personal data or for the administration of justice;
if we need to share personal data in order to establish, exercise or defend our legal rights (this includes providing personal data to others for the purposes of preventing fraud);
where we restructure, sell or transfer our business (or a part of it). For example in connection with a takeover or merger.
How long we use personal data for
We will not keep your personal data longer than we need to, how long this is depends on several factors, including:
Why we collected it in the first place;
How old it is;
Whether there is a legal/regulatory reason for us to keep it;
Whether we need it to protect you or us.
Cookies and similar technologies
Cookies are small text files containing a unique identifier, which are stored on your computer or mobile device so that your device can be recognised when you are using a particular website or mobile app. They can be used only for the duration of your visit or they can be used to measure how you interact with services and content over time. Cookies help to provide important features and functionality on our Website, and to improve your customer experience.
When you consent to Cookies on our Services, these may be used to do the following:
Improve the way our Website works
Cookies allow us to improve the way our Website so that we can personalise your experience and allow you to use many of their useful features.
Improve the performance of our Website
Cookies can help us to understand how our Website is being used, for example, by telling us if you get an error messages as you browse.
These Cookies collect data that is mostly aggregated and anonymous.
Deliver relevant online advertising, including via social media
Cookies used for this purpose are often placed on our Websites by organisations providing specialist services to us. These Cookies may collect information about your online behaviour, such as your IP address, the website you arrived from and information about your purchase history or the content of your shopping basket. This means that you may see our adverts on our Websites and on other organisations’ websites. You may also see adverts for other organisations on our Websites.
To help us to deliver online advertising that is relevant to you, we may also combine data we collect through Cookies in the browser of your desktop computer or other devices with other data that we have collected.
Measuring the effectiveness of our marketing communications, including online advertising
Cookies can tell us if you have seen a specific advert, and how long it has been since you have seen it. This information allows us to measure the effectiveness of our online advertising campaigns and control the number of times you are shown an advert.
Third parties operating through our Website
Our key partners are listed below with information about the services they provide to us. This list is not exhaustive but it does include those partners with whom we have an established relationship and whose cookie technologies are most frequently deployed through our Services.
Measurement & Personalisation
To market to you via social media platforms and to enable social sharing and engagement on our websites. These companies may use your data for their own purposes, including to profile and target you with other advertising.
Your choices when it comes to Cookies
Web browser cookies
You can use your browser settings to accept or reject new Cookies and to delete existing Cookies. You can also set your browser to notify you each time new Cookies are placed on your computer or another device. You can find more detailed information about how you can manage Cookies through your browser’s help function.
If you choose to disable some or all Cookies, you may not be able to make full use of our Websites. For example, you may not be able to add items to your shopping basket, proceed to checkout, or use any of our products and services that require you to sign in.
You can also manage advertising related Cookies used on our Services by opting-out through the Service Providers listed in the table above or by visiting the YourOnlineChoices website. Where we display personalised adverts on other organisations’ websites, the AdChoices icon will usually be displayed. Clicking on this icon will provide you with specific guidance on how to control your online advertising preferences. More information is available on the YourAdChoices website.
Subject access rights
You have the right to see the personal data we hold about you. This is called a Subject Access Request.
If you would like a copy of the personal data we hold about you, please write to:
Data Protection Officer
68-70 Brighton Road
You can also email us at kim.ba[email protected]
Other data protection rights
In relation to your personal data, you also have the right to:
1. have inaccurate information corrected:Summary of the right: if you believe we hold inaccurate or missing information, please let us know and we will correct it.
2. object to our use of it:Summary of the right:general objection – We will then consider your objection to our use of your personal data. If on balance, your rights outweigh our interests in using your personal data, then we will at your request either restrict our use of it (see section 3 below) or delete it (see section 4 below).objection in relation to direct marketing – If you make such an objection, we will stop using your personal data for direct marketing purposes.
3. restrict our use of it:Summary of the right:There are several situations when you can restrict our use of your personal data, this includes (but is not limited to):- you have successfully made a general objection (listed in section 2 above).– you are challenging the accuracy of the personal data we hold.– we have used your personal data unlawfully, but you do not want us to delete it.
4. have us delete it:Summary of the right:There are several situations when you can have us delete your personal data, this includes (but is not limited to):we no longer need to keep your personal data;you have successfully made a general objection (listed in section 2 above);you have withdrawn your consent to us using your personal data (and we do not have any other grounds to use it);
we have unlawfully processed your personal data.
5. have us transfer or “port” a copy of it:Summary of the right:Data portability is your right to obtain and reuse the personal information that you have provided to us for your own purposes across different services.
6. complain to the data protection regulator:We’d like the chance to resolve any complaints you have, however you also have the right to complain to the UK data protection regulator (the “ICO”) about how we have used your personal data.Their website is https://ico.org.uk/for-the-public/raising-concerns. Their website also contains useful information about your privacy rights https://ico.org.uk/for-organisations/resources-and-support/your-data-matters