PRIVACY POLICY

Last updated Dec 31^st 2019.

This website is owned and operated by Liz Earle Associated Productions Ltd (t/.a Liz Earle Wellbeing), with company no. 08056210 and registered address at Beech House, Bank Lyndhurst, Hampshire, SO43 7FD. (“our”, “we”, “us” or “Liz Earle Wellbeing”). Liz Earle Wellbeing is independently run from Liz Earle Beauty Co. Ltd.

We are committed to protecting and respecting your privacy. This policy (“Privacy Policy”) sets out the types of personal data we collect and use, and how we may disclose that information.

1. Introduction

This Privacy Policy covers our collection, processing and use of personal data when you use our website: https://lizearlewellbeing.com/ (the “Website”).

When you supply any personal data to us we have legal obligations towards you in the way we use that data. We must collect the information fairly and explain to you how we will use it. For ease of reading, we have divided this Privacy Policy into several sections:

1. Introduction
2. What information do we collect?
3. How and why do we use/share your information
4. For How long do we keep your information
5. Security
6. Cookies
7. Your Rights
8. Contact Details

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice that we may provide at or around the time that we collect or process personal data about you so that you are fully aware of how and why we are using that data.

This Privacy Policy supplements other notices including our Website Terms and Conditions and is not intended to override or replace them.

By visiting our Website, you agree to its terms (including as amended from time to time) and this Privacy Policy. If, for any reason, you do not agree to the terms of this Privacy Policy, please stop using this Website.

We reserve the right to revise or amend this Privacy Policy at any time to reflect changes to our business or changes in the law. Where these changes are significant we will endeavour to e-mail all of our registered users to make sure that they are informed of such changes. However, it is your responsibility to check this Privacy Policy before each use of the Website.

Please note that our Website is not directed at children under the age of 13 (“Child” or “Children”) and we do not knowingly collect personal information about Children. If you believe we have collected personal information about your Child, you may contact us at [email protected] and request that we remove information about your Child.

2. What information do we collect?

What is personal data?

Where this Privacy Policy refers to ‘personal data’ it is referring to data about you from which you could be identified – such as your name, your date of birth, your contact details and even your IP address.

By law all organisations in the UK are obliged to process your personal data in certain ways and to ensure that you are given an appropriate amount of information about how they use it. You also have various rights to seek information from those organisations about how they are using your data, and to prevent them from processing it unlawfully. For more information about these rights, please see the ‘Your Rights’ section of this Privacy Policy.

Data we collect from you when you use our Website

When you use this Website (by filling in forms, registering to use our Website, subscribing to our service, or other social media functions on our Website) contact us by post, telephone, email or SMS, participate in a competition or promotion or report a problem with this Website, we may collect, store and use certain personal information that you disclose to us. The information we collect from you may include (but is not limited to) kinds of personal data about you which we have grouped together as follows:

• Identity Data: includes first name, last name, title.
• Company Data: includes name, company website.
• Contact Data: includes e-mail address, billing address, postal address, telephone number; and mobile number.
• Financial Data: includes details for invoicing.
• Transactional Data: includes details about payments to and from you and other details of products and Services you have purchased from us.
• Technical Data: includes IP address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website.
• Profile Data: includes your username and password, purchases or orders made by you, your interests, preferences and feedback.
• 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 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.

Updating your information

If you want to update the information you have previously given to us, you can contact us at email: [email protected]

3. How and why do we use/share your information

Collecting your information

Here are some examples about how we may use the information we collect about you:

• to provide you with a personalised browsing experience when using this Website;
• to allow you to participate in interactive features of our service, when you choose to do so;
• to provide you with the information, products and services that you request from us;
• to fulfil any contractual agreements between you and us;
• to comply with legal and regulatory requirements;
• to manage any account that you hold with us;
• to administer our site and for internal operations including troubleshooting, data analysis, testing, research, statistical and survey purposes; to ensure that content from this Website is presented in the most effective manner for you and for your computer; and
• to notify you about changes to this Website or our services; and
• as part of our efforts to keep our site safe and secure.

Why is Liz Earle Wellbeing allowed to use your information in this way?

We will only use your personal data in the following circumstances:

• Where you have asked us to do so, or consented to us doing so;
• Where we need to do so in order to perform a contract we have entered into with you;
• Where it is necessary for our legitimate interests (or those of a third party) and your fundamental rights do not override those interests; and
• Where we need to comply with a legal or regulatory obligation.

Sharing your information

Depending on how and why you provide us with your personal data we may share it in the following ways:

• we may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;
• with selected third parties including business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you (see “Service Providers” below) or for the purpose of sourcing you employment or engagements with a third party; and
• with analytics and search engine providers that assist us in the improvement and optimisation of this Website.

We will not share your information with third parties in order for that third party to provide direct marketing communications to you, unless it relates to a specific activity which we are undertaking with a third party (e.g. a competition) and you have provided your consent for such use. Such activity will have its own terms and conditions relating to the way in which your information may be used.

We may also disclose your personal information to third parties in the following events:

• if we were to sell or buy any business or assets, in which case we might disclose your personal information to the prospective seller or buyer of such business or assets;
• if Liz Earle Wellbeing or substantially all of its assets are acquired by a third party, in which case personal information held by us about our customers will be one of the transferred assets; and
• if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our Website Terms and Conditions or terms and conditions of supply and other agreements entered into with you; or to protect the rights, property, or safety of our company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Service Providers

Our service providers provide us with a variety of administrative, statistical, and technical services. We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we stipulate that they protect this information and do not use it for any other purpose. We take these relationships seriously and oblige all of our data processors to sign contracts with us that clearly set out their commitment to respecting individual rights, and their commitments to assisting us to help you exercise your rights as a data subject. The following is a list of our major service providers:

• Mailchimp
• Royal Mail
• Stripe
• GoCardless
• Google Analytics
• Warners Group

Links to third party sites

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Where may also provide links to third party websites that are not affiliated with https://lizearlewellbeing.com/. All third party websites are out of our control and are not covered by this Privacy Policy. If you access third party sites using the links provided, the operators of these sites may collect information from you that could be used by them, in accordance with their own privacy policies. Please check these policies before you submit any personal data to those websites.

4. For how long do we keep your information?

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.

Where you sign up to receive e-mail marketing from us we will retain your e-mail address after you ‘opt-out’ of receiving e-mails in order to ensure that we continue to honour and respect that request. To unsubscribe from marketing emails at any time, please click on the unsubscribe link at the bottom of any marketing email and update your account preferences. You may also contact us to inform us if you do not wish to receive any marketing materials from us.

In some circumstances you can ask us to delete your data: see ‘Your Rights’ 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.

5. Security

We take the protection of your information very seriously. We use encryption (SSL) to protect your personal data when appropriate, and all the information provided to us is stored on secure servers once we receive it.

We may store your personal data on secure servers either on our premises or in secure third party data centres.

Please note that some of our service providers may be based outside of the European Economic Area (the “EEA”). These service providers may work for us or for one of our suppliers and may be engaged in, among other things, the fulfilment of your request for information, products and services, the processing of your payment details and the provision of support services. By submitting your personal information, you agree to this transfer, storing or processing. Where we transfer your data to a service provider that is outside of the EEA we seek to ensure that appropriate safeguards are in place to make sure that your personal data is held securely and that your rights as a data subject are upheld. If you would like more information about how the mechanism via which your personal data is transferred, please contact [email protected].

All payments for products and services are provided through our trusted third party payment service providers Stripe and GoCardless. Please see their terms and conditions for further information on the way they treat your payment details.

Where we have given you (or where you have chosen) a password, which enables you to access certain parts of this Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

6. Cookies

A cookie is a text-only string of information that a website transfers to the cookie file of the browser on your computer’s hard disk so that the website can remember who you are.

A cookie will typically contain the name of the domain from which the cookie has come, the ‘lifetime’ of the cookie, and a value, usually a randomly generated unique number.

A cookie can be classified by its lifespan and the domain to which it belongs. By lifespan, a cookie is either a:

• Session cookie. Temporary cookie that remains in the cookie file of your browser until you leave the website.
• Persistent cookie. This remains in the cookie file of your browser for much longer (though how long will depend on the lifetime of the specific cookie).

As for the domain to which it belongs, there are either:

• First-party cookies. These cookies are issued from the website you have accessed and often serve to give memory about your data and preferences.
• Third-party cookies. These are stored by a different domain to the visited page’s domain.

Find out more about cookies by contacting us at [email protected] or visit www.allaboutcookies.org.

How we use cookies on our Website and what information we collect

• Strictly necessary cookies. These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website or make use of e-billing services.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our Website. This enables us to personalise our content for you and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our Website, the pages you have visited and the links you have followed.

We use Google Analytics to collect information about you in aggregated form to help us understand how the Website is being use and to help us customise the Website for you. For more information about Google’s privacy policy, please visit http://www.google.com/intl/en/policies/. If you do not wish to allow the use of Google Analytics cookies at all, Google provides an opt-out plug-in for most common website browsers http://tools.google.com/dlpage/gaoptout.

Disabling or enabling cookies

You have the ability to accept or decline cookies by modifying the settings in your browser. However, you may not be able to use all the interactive features of our Website if cookies are disabled.

You can find more information about the individual cookies we use and the purposes for which we use them by emailing [email protected].

7. Your Rights

As a data subject you have a number of rights in relation to your personal data. Below, we have described the various rights that you have, as well as how you can exercise them.

Right of Access

You may, at any time, request access to the personal data that we hold which relates to you (you may have heard of this right being described as a “subject access request”).

Please note that this right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data.

You can exercise this right at any time by writing to us using the contact details set out in section 8 and telling us that you are making a subject access request. You do not have to fill in a specific form to make this kind of request.

Your Right to Rectification and Erasure

You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate. You may also ask us to erase personal data if you do not believe that we need to continue retaining it (you may have heard of this right described as the “right to be forgotten”).

Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is right. Further, we are not always obliged to erase personal data when asked to do so; if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to erase we will tell you what that reason is at the time we respond to your request.

You can exercise this right at any time by writing to us using the contact details set out in section 8 and telling us that you are making a request to have your personal data rectified or erased and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request.

Your Right to Restrict Processing

Where we process your personal data on the basis of a legitimate interest (see the section of this Privacy Policy which explains why we use your personal data) you are entitled to ask us to stop processing it in that way if you feel that our continuing to do so impacts on your fundamental rights and freedoms or if you feel that those legitimate interests are not valid.

We may process your personal data for the following reasons on the basis of a ‘legitimate interest’:

• To deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (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 (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)
• Asking you to leave a review or take a survey (to keep our records updated and to study how customers use our products/services);
• Collect and recovery money owed (to recover debts due to us);
• To administer and protect our business and website, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data (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 restricting exercise)
• To make suggestions and recommendations to you about goods or services that may be of interest to you (to develop our products/services and grow our business)

You may also ask us to stop processing your personal data (a) if you dispute the accuracy of that personal data and want us verify that data’s accuracy; (b) where it has been established that our use of the data is unlawful but you do not want us to erase it; (c) where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it in order to enable you to establish, exercise or defend legal claims.

Please note that if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to stop processing, we will tell you what that reason is, either at the time we first respond to your request or after we have had the opportunity to consider and investigate it.

You can exercise this right at any time by writing to us using the contact details set out in section 8 and telling us that you are making a request to have us stop processing the relevant aspect of your personal data and describing which of the above conditions you believe is relevant to that request. You do not have to fill in a specific form to make this kind of request.

Your Right to Portability

Where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party you may write to us and ask us to provide it to you in a commonly used machine-readable format.

Because of the kind of work that we do and the systems that we use, we do not envisage this right being particularly relevant to the majority of individuals with whom we interact. However, if you wish to transfer your data from us to a third party we are happy to consider such requests.

Your Right to stop receiving communications

For details on your rights to ask us to stop sending you various kinds of communications, please contact us using the details set out in section 8 .

Your Right to object to automated decision making and profiling

You have the right to be informed about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.

Exercising your rights

When you write to us making a request to exercise your rights we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity.

It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be, the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information then we may delay actioning your request until you have provided us with additional information (and where this is the case we will tell you).

8. Contact Details

If you have any queries regarding this Privacy Policy, if you wish to exercise any of your rights set out above or if you think that the Privacy Policy has not been followed, please contact:

Liz Earle Associated Productions Ltd (t/.a Liz Earle Wellbeing), with company no. 08056210 and registered address at Beech House, Bank Lyndhurst, Hampshire, SO43 7FD.

Alternatively you can contact us by emailing [email protected] or by completing the form here.