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PRIVACY POLICY

Welcome to the FRANK’S REMEDIES Ltd privacy notice.

FRANK’S REMEDIES respects your privacy and is committed to protecting your personal data. This privacy notice 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 notice is provided in a section format so you can click through to the specific areas set out below. Please also use the Glossary at the back of the notice to understand the meaning of some of the terms used in this privacy notice.

 

  1. IMPORTANT INFORMATION AND WHO WE ARE 
  2. THE DATA WE COLLECT ABOUT YOU AND HOW WE USE YOUR PERSONAL DATA
  3. HOW IS YOUR PERSONAL DATA COLLECTED
  4. SHARING AND TRANSFERS
  5. MARKETING AND OPTING OUT
  6. DATA SECURITY
  7. DATA RETENTION
  8. YOUR LEGAL RIGHTS
  9. GLOSSARY
  10. CONTACTING US

 

    1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how FRANK’S REMEDIES collects and processes your personal data through your use of our website, your participation in a FRANK’S REMEDIES event, or any data you may provide when you sign up to our newsletter, purchase a product or service or take part in a competition.

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

 

CONTROLLER

FRANK’S REMEDIES Ltd is the controller and responsible for your personal data (referred to as “FRANK’S REMEDIES”, “we”, “us” or “our” in this privacy notice).

If you have any questions in relation to this privacy notice, including any requests to exercise your legal rights, please email info@franksremedies.com

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on [01.12.2020] and historic versions can be obtained by contacting us.

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.

 

      1. THE DATA WE COLLECT ABOUT YOU AND HOW WE USE YOUR PERSONAL DATA

Personal data 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).

The categories of personal data about you we may collect, store and use are set out in the table below and in each case we have specified what we use it for and our ‘lawful basis’ for processing it. The law specifies certain ‘lawful bases’ under which we are allowed to use your personal data. Most commonly, we will use your personal data under the following lawful bases:

      1. Where we need to perform the contract we have entered into with you;
      2. Where we need to comply with a legal obligation;
      3. 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; and/or
      4. Where you have consented to us doing so.

 

 

Type of personal data

What we use it for

Our lawful basis for using it

Identity Data: first name, maiden name, last name, username or similar identifier, title, date of birth and gender, transaction ID

 

Contact Data: billing address, delivery address, email address, telephone number(s)

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

(i)To register you as a new customer.

 

(ii)To process and deliver your order including managing payments, fees and charges and collecting and recovering money owed to us.

 

(iii)To manage our relationship with you including notifying you about changes to our terms or privacy notice, and asking you to leave a review or take a survey.

 

 

(iv)To manage our after sales relationship with you, including contacting you in relation to any product recall.

 

 

 

 

(v)To enable you to take part in a prize draw, competition or complete a survey.

 

 

 

 

 

 

(vi)To administer and protect our business and this website.

 

 

 

 

 

 

(vii)To make suggestions and recommendations to you about goods or services that may be of interest to you.

(i)Performance of our contract with you.

 

(ii)Performance of our contract with you and our legitimate interests in recovering debts due to us.

 

 

 

(iii)Performance of our contract with you, compliance with a legal obligation to which we are subject, and our legitimate interests in keeping our records updated and studying how our customers use our products/services.

 

(iv)Performance of our contract with you, compliance with a legal obligation to which we are subject, and our legitimate interests in maintaining our relationship with our customers.

 

(v)Performance of our contract with you and our legitimate interests in studying how our customers use our products/services and developing and growing our business.

 

(vi)Compliance with a legal obligation to which we are subject and our legitimate interests in running our business in a proper manner, security and fraud prevention.

 

(vii)Your consent, or when you shop with us and do not choose to opt out from receiving our emails, our legitimate interests in developing and growing our business. 

Financial Data: bank account and payment method details.

 

Transaction Data: details about payments to and from you and other details of products and services you have purchased from us

 

 

 

 

 

(i)To process and deliver your order including managing payments, fees and charges and collecting and recovering money owed to us.

 

(ii)To manage our after sales relationship with you, including contacting you in relation to any product recall.

 

 

(i)Performance of our contract with you and our legitimate interests in recovering debts due to us.

 

 

 

 

(ii)Performance of our contract with you, compliance with a legal obligation to which we are subject, and our legitimate interests in maintaining our relationship with our customers.

 

Profile Data: username and password, purchases or orders made by you, your interests, and feedback

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

(i)To manage our relationship with you including notifying you about changes to our terms or privacy notice, and asking you to leave a review or take a survey.

 

 

 

(ii)To manage our after sales relationship with you, including contacting you in relation to any product recall.

 

 

 

 

(iii)To enable you to take part in a prize draw, competition or complete a survey.

 

 

 

 

 

 

(iv)To make suggestions and recommendations to you about goods or services that may be of interest to you.

 

(i)Performance of our contract with you, compliance with a legal obligation to which we are subject, and our legitimate interests in keeping our records updated and studying how our customers use our products/services.

 

(ii)Performance of our contract with you, compliance with a legal obligation to which we are subject, and our legitimate interests in maintaining our relationship with our customers.

 

(iii)Performance of our contract with you and our legitimate interests in studying how our customers use our products/services and developing and growing our business.

 

(iv)Your consent, or when you shop with us and do not choose to opt out from receiving our emails, our legitimate interests in developing and growing our business. 

 

Usage Data: information about how you use our website, products and services

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

(i)To enable you to take part in a prize draw, competition or complete a survey.

 

 

 

 

 

 

(ii) To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

 

 

 

 

 

 

(iii)To make suggestions and recommendations to you about goods or services that may be of interest to you.

 

 

(i)Performance of our contract with you and our legitimate interests in studying how our customers use our products/services and developing and growing our business.

 

(ii) Our legitimate interests in defining types of customers for our products and services, to keep our website updated and relevant, studying how our customers use our products/services and developing and growing our business.

 

(iii)Your consent, or when you shop with us and do not choose to opt out from receiving our emails, our legitimate interests in developing and growing our business. 

 

Marketing and Communications Data: your preferences in communication, how you interact with our email communications and receiving marketing from us

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

(i)To manage our relationship with you including notifying you about changes to our terms or privacy notice, and asking you to leave a review or take a survey.

 

 

 

 

 

(ii)To enable you to take part in a prize draw, competition or complete a survey.

 

 

 

 

 

(iv)To make suggestions and recommendations to you about goods or services that may be of interest to you.

 

 

 

(i)Performance of our contract with you, compliance with a legal obligation to which we are subject, and our legitimate interests in keeping our records updated and studying how our customers use our products/services.

 

 

 

(ii)Performance of our contract with you and our legitimate interests in studying how our customers use our products/services and developing and growing our business.

 

(iv)Your consent, or when you shop with us and do not choose to opt out from receiving our emails, our legitimate interests in developing and growing our business. 

 

 

 

 

Technical Data: 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.

 

 

 

 

 

(i)To administer and protect our business and this website. 

 

 

 

 

 

 

 

(ii) To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(i)Compliance with a legal obligation to which we are subject and our legitimate interests in running our business in a proper manner, security and fraud prevention.

 

(ii) Our legitimate interests in defining types of customers for our products and services, to keep our website updated and relevant, studying how our customers use our products/services and developing and growing our business.

 

 

 

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 notice.

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.

 

    1. HOW IS YOUR PERSONAL DATA COLLECTED

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact, Transaction, and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • Buy or express an interest in our products or services, in-store or on our website;
    • Create an account on our website;
    • Subscribe to our newsletter;
    • Request that we send marketing materials to you;
    • Enter a competition, promotion or survey;
    • Attend a FRANK’S REMEDIES promotional event;
    • Submit a product review;
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

 

  1. SHARING AND TRANSFERS

We may share your personal data for the purposes set out above where this is required by law, where it is necessary to perform our contract with you, or where we have another legitimate interest in doing so.

We may share your personal data with third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with applicable law or judicial process or if we reasonably believe that disclosure is necessary to protection our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.

 

  1. MARKETING AND OPTING OUT

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can update your marketing preferences by contacting us at info@franksremedies.com. You may also click ‘unsubscribe’ in any of the marketing emails we send to you.

Opting out of marketing messages will not prevent you receiving non-marketing messages from us, for example relating to products ordered from us, responses to customer service queries etc.

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Transaction, Usage 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 (this is “marketing”).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing. You will also receive marketing communications from us if you have provided us with your details when you entered a competition or registered for a promotion and gave us your consent as part of that process.

COOKIES

Your browser is where your cookie information is stored. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. Each browser has a different method for you to delete cookies or edit your privacy settings. If you disable or refuse cookies, please note that some parts of this website may become

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.

 

  1. 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.

 

  1. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

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.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax purposes. We also keep this basic information about our customers for seven years following your most recent active interaction with us, to enable us to deal efficiently with any after-sales queries that you may have. We also need to keep basic information for warranty purposes for a period of seven years and recall purposes for a period of seven years. We keep customer profile information that you have indicated you are happy for us to have in order to keep you up to date regarding our products, services and events and will keep this information until such time as you indicate you no longer wish us to keep this data.

In some circumstances you can ask us to delete your data: see [Request erasure] 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.

 

  1. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. To exercise one of the below rights, please contact us on info@franksremedies.com.

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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. In such circumstances we may reserve the right to delete your personal data rather than hold it but restrict processing, where our processes are not set up to enable a restriction.

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.

Request to opt out of automated profiling of your personal data. You have the legal right to opt-out of any automated profiling of your personal data that could have a legal consequence for you, and have a human being involved in the processing decision rather than it being automated. The only profiling of this type that we undertake is in our marketing activities, in which we tailor our marketing communications to your transactional history and product preferences. If you wish to opt-out of this automated profiling please contact us, though please be aware that our systems are not configured to send un-tailored marketing communications to you, so in practice opting out of automated profiling will result in you being opted out of receiving marketing communications from us.

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.

You also have the right to make a complaint at any time to a supervisory authority for data protection issues.

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 may 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.

 

  1. GLOSSARY

LAWFUL BASIS

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. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Consent means you have explicitly given us permission to process your personal data. In such circumstances we will have asked you a specific question and you will have entered information or ticked a tick-box to indicate your consent.

 

  1. CONTACTING US

If you have any questions OR would like more information about FRANK’S REMEDIES privacy policy, please e-mail info@franksremdies.com

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