PRIVACY POLICY

INTRODUCTION  

Welcome to Worthy Gal’s privacy policy.

Worthy Gal respects your privacy and is 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.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below.

1.  IMPORTANT INFORMATION AND WHO WE ARE  

PURPOSE OF THIS PRIVACY POLICY  

This privacy policy aims to give you information on how Worthy Gal collects and processes personal data through your use of this website, including any data you may provide through this website when you engage with us for the delivery of our services.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy 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 other notices and privacy policies and is not intended to override them.

Where we manage personal data, we identify as a Data Controller and recognise and act on our obligations under applicable data protection law. We are registered with the Information Commissioner’s Office as a Data Controller.

We have appointed INSERT NAME a data protection officer 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 DPO using the details set out below.

WHO WE ARE?  

INSERT DOMAIN ADDRESS is a site operated by Worthy Gal Limited under the trading name of Worthy Gal (“We”)

We are registered in England and Wales under company number 11765745 and have our registered office at 20-22, Wenlock Road, London, England, N1 7GU


CONTACT DETAILS
  

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

Insert Name: INSERT

Email address: info@worthygal.com

Postal address:  20-22, Wenlock Road, London, England, N1 7GU

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
  

We keep our privacy policy under regular review. This version was last updated on 25/03/2020.

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.


2.
  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 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.
     

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 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.

3.  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.


Emails.
We retain copies of emails sent to us and any personal information will be held in accordance with this Privacy Policy on the basis 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).


Telephone calls.
Calls to us may be recorded and any data relating to the call may be retained by us. The data will be held on the basis of being for our legitimate business needs or in order to fulfil our contractual obligations if you are a client of ours.


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.

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 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, in a 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.

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.

Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interest
To register you as a new customer   (a) Identity (b) Contact   Performance of a contract with you  
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   (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 administer and protect our business and this website (including troubleshooting, data 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, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation  
To make suggestions and recommendations to you about goods or services that may be of interest to you   (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications   Necessary for our legitimate interests (to develop our products/services 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, 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.

 THIRD-PARTY MARKETING  

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

OPTING OUT  

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.

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 INSERT LINK

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.

5.  DISCLOSURES OF YOUR PERSONAL DATA  

We don’t share, sell, or distribute your data to any of these third parties, except as contractually agreed with you or as provided in this Privacy Policy. We may disclose your personal information if we are required to do so by law, in connection with any legal proceedings, and in order to establish, exercise or defend our legal rights, or if otherwise legally permitted.

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.

6.  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.

7.  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.

8.  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.