Last Updated: 4/11/20
This website is not intended for children and we do not knowingly collect data relating to children.
Our Site is owned and operated by Worthy Gal Ltd, a company registered in England and Wales under company number 11765745 and whose registered address is 20-22 Wenlock Road, London, England, N1 7GU.
What this Policy covers
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.
- THE DATA WE COLLECT ABOUT YOU
What is personal data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as “any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier”.
Personal data is, therefore, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data and other online identifiers.
We may collect, use, store and transfer different kinds of personal data about you to meet legal obligations and for customer service purposes. We have grouped them together as follows:
- Identity Data may include first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data may include billing address, delivery address, email address and telephone numbers.
- Transaction Data may include details about payments to and from you and other details of products and services you have purchased from us.
- Profile Data may include your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Marketing and Communications Data may include your preferences in receiving marketing from us and our third parties and your communication preferences.
Data collected upon purchasing a digital product via Stripe payment gateway or Paypal;
a) At checkout, we will collect your name, email address, username, and password. This information is used to set up your account for our site. If you are redirected to an offsite payment gateway to complete your payment, we may store this information in a temporary session variable to setup your account when you return to our site.
b) At checkout, we may also collect your billing address and phone number. This information is used to confirm your credit card. The billing address and phone number are saved by our site to prepopulate the checkout form for future purchases and so we can get in touch with you if needed to discuss your order.
c) At checkout, we may also collect your credit card number, expiration date, and security code. This information is passed to our payment gateway to process your purchase.
For users that register on our website (if any), we may also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username themselves and will need to request the change via the site administrator of the site). Website administrators can also see and edit that information.
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.
2. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you, through:
- Contact Us. When using ‘Contact Us’ on our website we will collect your name, address, company name, email and phone number as well as your message, so that we can respond to your communications and provide details of our services and deal with general company enquiries. Data is held on the grounds of being legitimate to our business interests.
- Use of Services. When registering to use our services we will collect your details including name, address, email and phone number. Personal data is processed on the legal basis of entering into, or fulfilling, a contractual obligation and being for our legitimate business interests.
- Subscriptions to Newsletters. We will retain the information you provide to us if you subscribe to our newsletters via the website. This includes details of your name and email. Personal data is process on the lawful basis of your consent which may be withdrawn at any time (see Rights of Data Subject below).
- Other direct interactions. You may give us your data by filling in forms or by corresponding with us by post, or through social media. This includes personal data you provide when you: sign up to receive our free consultation; make enquiries or request information be sent to you; order our services; ask for information to be sent to you; engage with us on social media; contact us direct; or leave comments or reviews on our services.
- Social media. We use social media to engage with users and link to our Facebook, Instagram and Twitter pages. We do not keep any specific data that identifies you as an individual user but hold details of our followers on these platforms. You should refer to the Privacy Policies of these channels to understand how they treat your data in relation to linking to our site.
- Reviews. We may ask you for a review in relation to our services that may be used on our website or social media. Your personal details are not published.
- Visits to our website. When you visit our website we do not attempt to identify you as an individual user and we will not collect personal information about you unless you specifically provide this to us.
3. 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 obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before 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.
Purposes For Which We Will Use Your Personal Data
We have set out below 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.
Please contact us 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.
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, 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 call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences.
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.
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.
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.
4. DISCLOSURES OF YOUR PERSONAL DATA
In the event that our business or any part of it is sold or integrated with another business, your details will be disclosed to our advisers and those of any prospective purchaser and will be passed to the new owners of the business.
5. 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.
We will report any unlawful breach of data as required by the GDPR within 72 hours of the breach occurring, if it is considered that there is an actual, or possibility, that data within our control including the control of our data processors, has been compromised.
If the breach is classified as ‘high risk’ we will notify all data subjects concerned using an appropriate means of communication. We will report any relevant breaches to the ICO, see below.
6. DATA RETENTION
How Long Will You Use My Personal Data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
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 could 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 could 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.
Your Legal Rights
You have the right to:
- 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.
- Request correction of the 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.
- 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 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.
- 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.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- 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.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the 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. 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.
- 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.
- Website browsing recordings – please note, some website sessions may be recorded, all personal data will be hidden.