1.  Introduction

1.1    We are committed to safeguarding the privacy of our website visitors.

1.2    This policy applies where we are acting as a data controller with respect to the personal data of our website visitors; in other words, where we determine the purposes and means of the processing of that personal data.

1.3    We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website, we will ask you to consent to our use of cookies when you first visit our website.

1.4   In this policy, “we”, “us” and “our” refer to Hardy Labels.

2. Credit

2.1    This document was created using a template from SEQ Legal (https://seqlegal.com/free-legal-documents/privacy-policy).

3. The personal data that we collect

3.1    In this Section 3 we have set out the general categories of personal data that we process

3.2    We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is consent by you accepting non-essential cookies.

3.3    We may process your website user account data (“account data“). The account data may include your name, address and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent which is explicitly requested when you place an order with us.

3.4    We may process information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

3.5    We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

3.6    We may process information relating to transactions, including purchases of goods and/or services, that you enter into with us and/or through our website (“transaction data“). The transaction data may include your contact details, your card details and the transaction details. The source of the transaction data is you and/or our payment services provider. The transaction data may be processed for the purpose of supplying the purchased goods and/or services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract; providing that, if you are not the person contracting with us, the legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

3.7    We may process information that you provide to us for the purpose of subscribing to our email notifications (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.8    We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.9    We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

3.10  In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

3.11  Please do not supply any other person’s personal data to us, unless we prompt you to do so.

  1. Purposes of processing and legal bases

4.1     In this Section 4, we have set out the purposes for which we may process personal data and the legal bases of the processing.

4.2     Operations – We may process your personal data for the purposes of operating our website, the processing and fulfilment of orders, providing our services, supplying our goods, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

4.3     Relationships and communications – We may process contact data, account data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of relationships, and the proper administration of our website, services and business.

4.4     Research and analysis – We may process usage data and/or transaction data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.

4.5     Record keeping – We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.

4.6     Security – We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.

4.7     Insurance and risk management – We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

4.8     Legal claims – We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

4.9     Legal compliance and vital interests – We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.

  1. Providing your personal data to others

5.1    We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5.2    Your personal data held in our website database will be stored on the servers of our hosting services providers Hostinger identified at www.hostinger.com.

5.3    We may disclose your name and email address to Trustpilot identified at https://uk.trustpilot.com insofar as reasonably necessary for them to request that you leave a review for our website.

5.4    Financial transactions relating to our website and services are handled by our payment services provider, Stripe. We will share transaction data with our payment services provider only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at https://stripe.com/gb/privacy.

5.5    Usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use are shared with the Google Analytics service via cookies.  This usage data may be processed for the purposes of analysing the use of the website and services.

5.6   IP address information is shared with the Google Fonts service in order to provide fonts to your web browser.

5.7    In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

  1. International transfers of your personal data

6.1    In this Section 6, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

6.2    The hosting facilities for our website are situated in UK, US, Brazil, Netherlands, Singapore, Indonesia and Lithuania.  Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.  In particular our hosting company Hostinger have concluded with the data processors and/or sub-processor relevant agreements on such data transfers outside EU or EEA, which comply with the European Commission approved standard contractual clauses for data transfers from data controllers in the EU to data processors and/or controllers established outside the EU or European Economic Area (EEA).

6.3    You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

  1. Retaining and deleting personal data

7.1    This Section 7 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

7.2    Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

7.3    We will retain your personal data as follows:

(a)    Usage data will be retained for a minimum period of 12 months following the date of collection, and for a maximum period of 24 months following that date;

(b)    account data will be retained for a minimum period of 12 months following the date of closure of the relevant account, and for a maximum period of 24 months following that date;

(c)    publication data will be retained for a minimum period of 1 month following the date when the relevant publication ceases to be published on our website or through our services, and for a maximum period of 3 months following that date;

(d)    enquiry data will be retained for a minimum period of 12 months following the date of the enquiry, and for a maximum period of 24 months following that date;

(e)    transaction data will be retained for a minimum period of 12 months following the date of the transaction, and for a maximum period of 24 months following that date;

(f)    notification data will be retained for a minimum period of 12 months following the date that we are instructed to cease sending the notifications, and for a maximum period of 24 months following that date (providing that we will retain notification data insofar as necessary to fulfil any request you make to actively suppress notifications); and

7.4    Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

  1. Your rights

8.1    In this Section 8, we have listed the rights that you have under data protection law.

8.2    Your principal rights under data protection law are:

(a)    the right to access – you can ask for copies of your personal data;

(b)    the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

(c)    the right to erasure – you can ask us to erase your personal data;

(d)    the right to restrict processing – you can ask use to restrict the processing of your personal data;

(e)    the right to object to processing – you can object to the processing of your personal data;

(f)    the right to data portability – you can ask that we transfer your personal data to another organisation or to you;

(g)    the right to complain to a supervisory authority – you can complain about our processing of your personal data; and

(h)    the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

8.3    These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.

8.4    You may exercise any of your rights in relation to your personal data by written notice to us, by using the contact details on our website.

  1. About cookies

9.1    A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

9.2    Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

9.3    Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

  1. Cookies that we use

10.1    We use cookies for the following purposes:

(a)    authentication and status – we use cookies to identify you when you visit our website and as you navigate our website, and to determine if you are logged into the website;

(b)    personalisation – we use cookies to store information about your preferences, items in your shopping cart and to personalise the website for you;

(c)    analysis – we use cookies to help us to analyse the use and performance of our website and services; and

(d)    cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.

Please refer to the cookie policy for a list of the cookies used on this site.

  1. Cookies used by our service providers

11.1  Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

11.2  We use Google Analytics. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google’s use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google’s privacy policy at https://policies.google.com/privacy. The relevant cookies are listed in the cookies policy.

11.3 We use Stripe to provide order payment services. This service uses cookies to facilitate payment of your order. You can view the privacy policy of this service provider at https://stripe.com/gb/privacy. The relevant cookies are listed in the cookies policy.

11.4  We use Trustpilot to provide purchase review services and associated reporting. This service uses cookies to provide a review service for our website. You can view the privacy policy of this service provider at https://uk.legal.trustpilot.com/for-reviewers/end-user-privacy-terms.  The relevant cookies are listed in the cookies policy.

  1. Managing cookies

12.1  Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a)    https://support.google.com/chrome/answer/95647 (Chrome);

(b)    https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c)    https://help.opera.com/en/latest/security-and-privacy/ (Opera);

(d)    https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e)    https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and

(f)    https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

12.2  Blocking all cookies will have a negative impact upon the usability of many websites.

12.3  If you block cookies, you will not be able to use all the features on our website.

  1. Amendments

13.1  We may update this policy from time to time by publishing a new version on our website.

13.2  You should check this page occasionally to ensure you are happy with any changes to this policy.

  1. Our details

14.1 This website is owned and operated by Alison Warner trading as Hardy Labels.