THE SHORT AND EASY-TO-UNDERSTAND VERSION
We love plain English just as much as you do, so we’ve summarised all of the legal blurb below into the most important points for you:
- Your data is safe with us. We don’t sell it, license it or share it. Never have done, never will.
- If you sign up for our mailing list, we know your first name and your email address. We will then send you content-packed emails about 4-5 times per month, which act as an extension of the free educational experience you signed up for. These emails may occasionally also contain opportunities to buy other products and services.
- If you enrol for a course with us, we know your first name, last name and email address. We also ask you for your address and phone number in case we need to contact you in other ways, although we generally don’t send anything by post. We will then send you a monthly student newsletter, filled with information and extracurricular information that can help with your courses. These emails may occasionally also contain opportunities to buy other products and services.
- We will upload your data to Facebook Ads so that we can show you articles, webinar invites and offers that you might find interesting through social media. Facebook doesn’t save that data; it immediately deletes it once the system has created our advertising audience. You can choose to disable this targeted advertising in Facebook in your privacy settings.
- If you want to see what data we hold on you, you can contact us any time at [email protected]and we’ll be happy to help. We can tell you what data we hold, we can change that data, we can restrict how we contact you. We are also happy to permanently delete any data we hold on you if you ask us to.
- If you want to opt-out of communications from Formula Botanica, this is processed immediately by clicking on the opt-out link at the bottom of any of the emails we send you.
THE LEGAL VERSION
Herb & Hedgerow Ltd (“us”, “we”, or “our”) operates the https://formulabotanica.com website (the “Service”). We trade under the name Formula Botanica.
This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.
PERSONAL DATA: Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
USAGE DATA: Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
COOKIES: Cookies are small pieces of data stored on a User’s device.
DATA CONTROLLER: Data Controller means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed.
DATA PROCESSOR (OR SERVICE PROVIDERS): Data Processor (or Service Provider) means any person (other than an employee of the Data Controller) who processes the data on behalf of the Data Controller.
We may use the services of various Service Providers in order to process your data more effectively.
DATA SUBJECT: Data Subject is any living individual who is the subject of Personal Data.
USER: The User is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.
2. Information Collection And Use
We collect several different types of information for various purposes to provide and improve our Service to you.
TYPES OF DATA COLLECTED
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Such Personal Data may include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Address, State, Province, ZIP/Postal code, City
- Cookies and Usage Data
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.
We may also collect information how the Service is accessed and used. This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
We may use and store information about your location if you give us permission to do so. We use this data to provide features of our Service, to improve and customize our Service.
You can enable or disable location services when you use our Service at any time, through your device settings.
TRACKING & COOKIES DATA
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
- Session Cookies. We use Session Cookies to operate our Service.
- Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
- Security Cookies. We use Security Cookies for security purposes.
3. Use of Data
We use the collected data for various purposes:
- To provide and maintain our Service
- To notify you about changes to our Service
- To allow you to participate in interactive features of our Service when you choose to do so
- To provide customer support
- To gather analysis or valuable information so that we can improve our Service
- To monitor the usage of our Service
- To detect, prevent and address technical issues
- To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
Formula Botanica has a number of lawful reasons that we can use (or ‘process’) your personal information. One of the lawful reasons is called ‘legitimate interests’.
Broadly speaking legitimate interests means that we can process your personal information if ee have a genuine and legitimate reason and we are not harming any of your rights and interests
So, what does this mean? When you provide your personal details to us we use your information for our legitimate business interests to educate, teach and raise awareness of green and organic beauty-related issues. Before doing this, though, we will also carefully consider and balance any potential impact on you and your rights.
Some typical examples of when we might use the approach are for preventing fraud, direct marketing, maintaining the security of our system, data analytics, enhancing, modifying or improving our services, identifying usage trends and determining the effectiveness of our campaigns and fundraising.
Formula Botanica will process the personal information you have supplied to us to conduct and manage our business to enable us to give you the most appropriate marketing, information, service and products and provide the best and most secure educational experience. These are what we consider to be our ‘Legitimate Interests’.
The following are some examples of when and why we would use this approach in our work:
- Marketing: We will send email marketing which further the aims and objectives of Formula Botanica to drive and grow the global green beauty movement. We will also make sure our email marketing is relevant for you, tailored to your interests.
- Enrolling online: In order for us to process an enrolment, payment has to be taken and contact information collected, such as name, delivery address and telephone number, provided. We also record the transaction.
- Your best interest: Processing your information to protect you against fraud when transacting on our website, and to ensure our websites and systems are secure.
- Personalisation: Where the processing enables us to enhance, modify, personalise or otherwise improve our services/communications for the benefit of our students and followers.
- Analytics: To process your personal information for the purposes of customer analysis, assessment, profiling and direct marketing, on a personalised or aggregated basis, to help us with our activities and to provide you with the most relevant information as long as this does not harm any of your rights and interests.
- Research: To determine the effectiveness of promotional campaigns and advertising and to develop our products, services, systems and relationships with you.
- Due Diligence: We may need to conduct investigations on supporters, potential customers and business partners to determine if those companies and individuals have been involved or convicted of offences such as fraud, bribery and corruption.
We will also hold information about you so that we can respect your preferences for being contacted by us.
When we process your personal information for our legitimate interests, we will consider and balance any potential impact on you and your rights under data protection and any other relevant law. Our legitimate business interests do not automatically override your interests – we will 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).
Remember, you can change the way you hear from us or withdraw your permission for us to process your personal details at any time by using our contact form on the Contact page on our website.
4. Retention of Data
We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
5. Transfer Of Data
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside United Kingdom and choose to provide information to us, please note that we transfer the data, including Personal Data, to United Kingdom and process it there.
6. Disclosure Of Data
DISCLOSURE FOR LAW ENFORCEMENT
Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
We may disclose your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend our rights or property
- To prevent or investigate possible wrongdoing in connection with the Service
- To protect the personal safety of users of the Service or the public
- To protect against legal liability
We may share your Personal Data with the following third parties:
- Service providers (acting as processors) who provide IT and system administration services.
- Professional advisers (acting as processors or joint controllers) including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based who require reporting of processing activities in certain circumstances.
7. Security Of Data
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute 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.
8. “Do Not Track” Signals
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
9. Your Rights
Under certain circumstances, you have rights under data protection laws in relation to your Personal Data.
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.
You can update your Personal Data directly within your account settings section. If you are unable to change your Personal Data, please contact us to make the required changes.
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.
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.
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.
10. Service Providers
We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service Providers to monitor and analyze the use of our Service.
- Google AdWords: Google AdWords remarketing service is provided by Google Inc.You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/adsGoogle also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/
- Facebook: Facebook remarketing service is provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings. For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation
We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).
The payment processors we work with are:
11. Links To Other Sites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
12. Children’s Privacy
Our Service does not address anyone under the age of 13 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
14. Contact Us
- By email: [email protected]
Email address: [email protected]
If you have a concern about the way we are collecting or using your personal data you should raise your concern with us in the first instance and then if still concerned contact the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).