1.1. Who we are
We are Simply Organic S.L. (VAT number ESB 63136659 with registered office address Carrer De Barcelona 28, El Masnou, Barcelona, Spain, 08320). This policy describes how we use your personal information.
We respect your privacy and value the trust you place in us when you share your personal information with us. This policy sets out how we, as Data Controller, collect, process, use and disclose your personal information, why we use it, with whom we share it, the rights to which you may be entitled and your choices about our use of your personal information.
This policy covers our use of your personal information arising from use of this website as well as buying / using our products and services. If you have any questions or need any further clarity please get in touch via email to email@example.com or by post to Carrer De Barcelona 28 El Mansou, Barcelona Spain, 08320.
1.2. Your information
1.2.1. DATA COLLECTION AND USAGE
Personal Data includes any data that can identify you as a person, or be used in conjunction with other information to identify you.
We comply with all applicable laws in relation to data protection and privacy, including the Data Protection Act 2018 and the General Data Protection Regulation (GDPR).
|What we collect||Lawful basis for Processing||How we use it|
|Information that you actively give us to make a purchase: Your contact details including: your name, address, email address and phone number;Your bank account or credit/ debit card details; The product or service purchased.||Performance of contract. We cannot perform our sales contract without this information.||We use this information to:Provide our products and services;Manage and administer our services;Process your order; Take payment from or give you a refund;Help us ensure that our customers are genuine and to prevent fraud.|
|Information that you actively give us to subscribe to our newsletter, receive information or mailings:Your name and email address.||Consent. You must provide Consent to sign up to our mailing lists.You can withdraw this Consent at any time. Please see below section 4 for more information.||Provide our products and services;Help us ensure that our customers are genuine and to prevent fraud; Send news on our offers, great value products and inspiring agricultural, planting and growing or gardening projects.|
|Information that you actively give us to sign up for a prize draw or competition:Your contact details including: your name, address, email address and phone number (this may include your social media account if that’s the way you communicate with us);||Legitimate Interest. We need this information to administer any prize draw competitions. Each competition will have Terms and Conditions, please consult them with any further questions.||Provide our products and services;Manage and administer prize draws, competitions and our services;Take payment from or give you a refund;Help us ensure that our customers are genuine and to prevent fraud.|
|Information when you communicate with us whether in person, through our website or via email, over the phone, through social media or via any other medium, including:Your contact details including: your name, address, email address and phone number (this may include your social media account if that’s the way you communicate with us);The details of your communications with us (including call recordings);The details of our messages to you.||Legitimate Interest. We cannot answer your communicatio n without this information.||We use this information, including to:Answer any issues or concerns;Monitor customer communications for quality and training purposes;Develop new products and services;Improve our products and services;Personalise our products and services;Regulatory compliance;|
|Information that we collect through your use of our website including:Device information such as operating system, unique device identifiers, the mobile network system;Hardware and browser settings;Date and time of requests;The requests you make;The pages you visit and search engine terms you use;IP address.Recordings of screen interactions and heatmaps.||Legitimate Interest. We use this information to deliver quality service and tailor your experience.||We use this information to:Provide our products and services;Develop new products and services;Improve our products and services;Personalise our products and services;Identify issues with the website and user’s experience of it;Make improvements to the user experience;Manage and administer our systems;Monitor the way our website is used.|
|Information that we collect incidentally from other sources or public sources, including:Information available in the media;Information presented on our social media timelines;Information collected by security systems;||Legitimate Interest. We use this information to deliver quality service.||We use this information, including to:Maintain market awareness;Build and maintain social media branding;Provide security to our sites;Fraud prevention and confirming your identity.|
|Information received from credit reference agencies.||Performance of contract. We cannot perform our sales contract without this information||Fraud prevention and confirming your identity.|
Simply Organic S.L does not knowingly collect data from any unsupervised person under the age of 18. If you are under the age of 18, you must not use the Homebase website or submit any Personal Data to us unless you have the consent of, and are supervised by, a parent or guardian.
1.2.2. LEGAL REQUIREMENTS
Your personal information may also be processed if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency or in the defence of a legal claims. We will not delete personal information if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved.
1.2.3. HOW LONG WE KEEP YOUR INFORMATION
We will keep your information for as long as it is reasonably necessary. It will depend on factors such as whether you have any outstanding purchases or have interacted with recent offers.
1.2.4. INFORMATION WE SHARE
There are certain circumstances where we may transfer your Personal Data to contractors, service providers, and to other parties.
- We may also share your information with certain contractors or service providers who assist us in the provision of products and services we supply to you, are involved in prize draws and competitions we run or provide other services to assist with our day-to-day operations. They may process your Personal Data for us, for example, if we use a marketing agency. Other recipient’s/service providers include manufacturers, logistics/delivery providers, advertising agencies, IT specialists, database providers, backup and disaster recovery specialists or email providers. Our suppliers and service providers will be required to meet our standards on processing information and security. The information we provide them, including your information, will only be provided in connection with the performance of their function.
- We may also share your information with certain third parties. We will do this either when we receive your Consent or because we need them to see your information to provide products or services to you. These include credit reference agencies, anti- fraud databases, screening agencies and other partners we do business with.
Your personal information may be transferred to other third party organisations in certain scenarios:
- If we’re discussing selling or transferring part or all of our business – the information may be transferred to prospective purchasers under suitable terms as to confidentiality;
- If we are reorganised or sold, information may be transferred to a buyer who can continue to provide services to you;
- If we’re required to by law, or under any regulatory code or practice we follow, or if we are asked by any public or regulatory authority – for example the Police;
- If we are defending a legal claim your information may be transferred as required in connection with defending such claim.
Your Personal Data may be shared if it is made anonymous and aggregated, as in such circumstances the information will cease to be personal data.
1.2.5. WHERE YOUR INFORMATION WILL BE HELD
Our offices are based in Barcelona (El Masnou), Spain and your data will be held on servers/systems accessible by this office.
We will only transfer data to jurisdictions outside the scope of the European General Data Protection Regulation (GDPR) where the appropriate safeguards set out in the GDPR are in place.
We are happy to provide you with copies of the regulator-approved standard contractual clauses, which you can request from us using the contact details below.
1.3. Your rights
1.3.1. DATA SUBJECT RIGHTS
We’ve listed the rights you have over your information and how you can use them below.
These rights will only apply in certain circumstances. Some of these rights will not be available if there are outstanding contracts between us, if we are required by law to keep the information or if the information is relevant to a legal dispute.
We will normally respond to or action (as applicable) requests within one month from receipt of your request. This period may be extended by 2 further months if necessary taking into account the complexity or number of requests. If this is the case, we will let you know within one month of your original request.
In general, the information or action requested will be provided free of charge. However, if requests are manifestly unfounded or excessive (or repetitive in nature) we may charge a fee (or alternatively refuse to deal with the request).
It is important that we establish that the individual right is being exercised by the correct person. Therefore, we may need to ask you for information in order to verify your identity prior to processing your request. This may include asking you to confirm certain details we hold about you (such as post code or first line of your address) or to provide proof of identification.
You have the right to make the following types of request regarding the Personal Data Simply Organic S.L holds about you:
- Right of access (subject access requests) – the right to request a copy of the Personal Data (if any) that we have concerning you and supporting information explaining how your Personal Data is used.
- Right of rectification – the right to request that we rectify inaccurate or incomplete Personal Data concerning you.
- Right of erasure (right to be forgotten) – the right, in some situations, to delete your Personal Data.
- Right to restrict processing – the right, in some situations, to request that we do not use the Personal Data you have provided (e.g. if you believe it to be inaccurate). This is intended as a temporary right until the reason for such restriction has been resolved or rectified.
- Right to data portability – the right, in some situations, to request that we transmit your data to you or another entity.
- Right to object – the right to object to certain processing of your Personal Data (unless we have overriding compelling grounds to continue the processing) and the right to object to direct marketing/profiling In certain circumstances, we will be exempted from responding to certain requests. We will use these exemptions to the extent appropriate.
The supervisory body for Data Protection in Spain ¿Where and who the Information Commissioner’s Office. They have information about your rights and how to enforce them, as well as processes for complaints.
1.4. How to contact us
1.4.1. GETTING IN CONTACT WITH US IS EASY
If you have any questions about this policy, please contact our Office at firstname.lastname@example.org.
If you want to be removed from the Simply Organic marketing list? Please contact our Office at email@example.com.
1.5. Changes to the policy
This policy may be changed from time to time and will be posted here. We encourage you to visit this area frequently to stay updated.
1.6. Other policies
In addition, cookies allow us to understand who has seen which pages and advertisements, to determine how frequently particular pages are visited and to determine the most popular areas of our website.
We are committed to keeping your personal information safe. We’ve got appropriate physical, technical and administrative measures in place to protect your information against accidental or unauthorised destruction, loss, access or alteration.
1.7. Glossary Data Controller
The person or organisation that determines when, why and how to process Personal Data. It is responsible for establishing practices and policies in line with the GDPR. We are the Controller of all Personal Data relating to our Company Personnel and Personal Data used in our business for our own commercial purposes.
1.7.1. PERSONAL DATA
Any information identifying a Data Subject or information relating to a Data Subject that we can identify (directly or indirectly) from that data alone or in combination with other identifiers we possess or can reasonably access. Personal Data includes Special Categories of Personal Data and Pseudonymised Personal Data but excludes anonymous data or data that has had the identity of an individual permanently removed. Personal data can be factual (for example, a name, email address, location or date of birth) or an opinion about that person’s actions or behaviour.
Agreement which must be freely given, specific, informed and be an unambiguous indication of the Data Subject’s wishes by which they, by a statement or by a clear positive action, signify agreement to the Processing of Personal Data relating to them.
1.7.3. LEGITIMATE INTEREST
Means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our Legitimate Interests.
1.7.4. PERFORMANCE OF CONTRACT
Means processing your data where it is necessary for the performance of a shopping transaction or marketing call to action on the website to work of which you are a party to and agree to.