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Privacy, Cookies And Data Policy
Clearwater Hampers Ltd – trading as Hampers.com - 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), purchase from us and tell you about your privacy rights and how the law protects you.
This privacy notice aims to give you information on how Clearwater Hampers Ltd collects and processes your personal data, including any data you may provide when you sign up to our marketing emails or purchase a product from Clearwater Hampers Ltd.
Where we are the “controller” of the personal data that we keep and use, Clearwater Hampers Ltd (company number 06167203) is the legal entity responsible for how your personal data is collected, stored and processed. (In this privacy notice, Clearwater Hampers Limited is collectively referred to as “Clearwater Hampers", "we", "us" or "our"). Clearwater Hampers Limited’s business address is 36 Innovation Drive, Milton Park, Abingdon, Oxfordshire, OX14 4RT (which is also our registered office). At Clearwater Hampers, the person with responsibility for our data protection compliance is Vitali Kamarovas (our Data Protection Officer). They can be contacted via email at [email protected] or by phone at 01235 604552.
When you share your personal information with us, you have a right to expect that information to be treated with total confidentiality. Whether you have supplied your personal details online, by phone, by email or in a letter, we will use your personal data for the purposes explained in this privacy notice and for which they were initially collected, and only with a lawful reason to do so.
Our main reason for collecting personal information (which may include names, addresses, contact details including email addresses and business information) will be for the fulfilment of orders made by you for our hampers/goods, and for marketing our business to you in the ways more fully explained below. We will collect appropriate personal information for you and as necessary of the intended recipient of the hampers/goods that you are purchasing
Where someone is receiving a hamper/goods that was ordered by someone else, we will not use personal information of the recipient of the hampers/goods for any purposes other than as necessary to fulfil the order made by you (which may include gift messages to a recipient’s email address or mobile phone number if this service is requested by you during the checkout process), or if we need to contact the recipient regarding an issue with the order, its delivery or any item included in the order.
Most commonly, we will use your personal data in the following circumstances:
- in performance of a contract (the agreement to provide hampers/goods); and/or
- for our legitimate interests where your interests and fundamental rights do not override those legitimate interests; and/or
- with your consent.
It is your responsibility to ensure that your personal data provided to us is accurate and up to date. You can update your personal contact details, including email address and phone number, by visiting My Account online or, by calling our customer services team on 01235 833732.
Clearwater Hampers is based in the UK and its business activities are run from our Abingdon office. Data is principally stored by us electronically and the servers that are used for our electronic storage are in the UK.
If your order is for delivery outside the EEA, it will be necessary to transfer your personal data outside the European Economic Area (the EEA) to complete (deliver) your order. We may transfer personal data outside of the EEA to processors acting on our behalf.
In some cases, countries outside the UK and EEA may not have such well-developed data protection laws as those in the UK and EEA. However, we will put in place adequate protections that require your personal data to be kept secure, confidential and to be processed only and strictly in line with the terms of this privacy notice and any relevant data protection laws. This may include by use of the standard contractual clauses adopted by the Information Commissioner’s Office (ICO) or the European Commission to protect personal data.
We may use your contact details (including your email and home address) to send you details of our latest products, promotions and other marketing messages (including by email) to keep you aware of what we're up to and to help you see and find our products. This would include sending details of special offers and promotions from Hampers.com. We also use marketing profiling techniques to determine product offers that may be of interest to you, whether that be by email or social media. For further information on how we use your personal data to keep you informed about our products and promotions and how you can change your marketing preferences, click the relevant sections below.
Once we have collected your personal data, we will always give you an easy way to opt-out of receiving marketing messages. We have lots of ways you can stop marketing messages in the future; the best way to do this is through your My Account settings on Hampers.com or to click on the 'unsubscribe' link in any email you receive from us.
Where we do rely on your consent to send you email marketing we will make it clear that we are asking for your consent. Where we rely on consent, you can withdraw this at any time by telling us that you wish to do so.
We will use your email address to send you targeted marketing information about our product offers and promotions via social media platforms. To do this, we will share your email address in a secure manner with social media organisations, who will match our advertising requirements to your social media profile. We have a legitimate business interest to send you product information via social media which we believe is of relevance to you; this is known as Interest-Based Advertising. However, should you wish to exercise your right to stop targeted social media marketing, you can do this at any time by changing your marketing preferences.
We actively use social media platforms as a way of connecting and getting closer to our customers to hear and understand what our customers think about us and our products and services. Occasionally, we may contact you directly via those social media platforms if we would like to share your comments or pictures with other customers or publish them in our marketing materials. We will always ask you if you are happy for us to use your data in this way and will keep any data that you provide to us, such as email address, confidential and secure.
We will not share your personal data with third party companies for the purpose of them marketing their products and services to you, apart from as set out above.
Any third party that communicates with you on our behalf must only do so for the purpose of carrying out the services and not for the purpose of direct marketing their own products and services. If you have any concerns about any of our third party processors and partners, please contact our customer services team on 01235 833732.
Profiling is a term used to describe a form of data processing where significant volumes of data made up of lots of different data types - such as browser history from Cookies, age, gender, size, transaction history, demographics and buying habits - are all used in an aggregated, anonymised and non-personalised form to evaluate and predict, based on statistical analysis, what customers may or may not want to purchase from us by assigning each customer to a profile type. We use this technique to understand what drives you to buy from us and the types of products you are most likely to be interested in whether that be by email or social media.
In order to fulfil your order and as part of delivering our products and services to you, we will share your personal data with carefully chosen third party processors and partners who carry out a number of services on our behalf.
For example, we will use your personal contact details such as name, postal address, phone number and email address that you provide to us in respect of delivering products or services to you. We will share this information with our suppliers who directly despatch orders to you or our delivery partners who may contact you to arrange a convenient delivery time and provide you with updates as to when they will arrive. We will also share your personal information as set out in our marketing sections above.
We will keep personal data only for as long as is necessary to fulfil the purposes for which we collected it. Normally our retention period is not more than 7 years from the last time that you purchased hampers/goods from us. Any personal data will not be used for marketing if you have asked us to stop providing marketing to you (other than to the extent necessary to prevent you from receiving further marketing.
We want to make sure that we only contact you with online content that you will find relevant and interesting. For this to work effectively, we collect information about your browsing activity using cookies when you are using our website. A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or another electronic device) when you use our website. These cookies pass back to us your browsing information using your Internet Protocol ("IP") address as the identifier, which we combine with other anonymised, non-personalised and aggregated data, allowing us to determine what content and product information is most relevant to you when you are shopping online.
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
You have the right to complain to the Information Commissioner, which you can do by contacting the ICO directly. Full contact details, including a helpline number, can be found on the ICO website (www.ico.org.uk). This website also has useful information on your rights and our obligations. However, please raise any concerns or issues with us first so that we may deal with this as quickly as possible for you.
Under certain circumstances, you have the right by law to request:
- access to your personal data. This enables you to ask to receive a copy of the personal data that we hold about you and to check that we are lawfully processing it.
- erasure of your personal data.
- object to processing of your personal data where we are relying on our legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- correction of the personal data that we hold about you.
- right to withdraw your consent (if that is the lawful basis for our use of your personal data).
- restriction of processing of your personal data.
- transfer of your personal data to another party.
You may wish to access a copy of the personal data we hold about you - known as a Subject Access Request. You can do so by submitting a request in writing to the Data Protection Manager. 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 may refuse to comply with your request in these circumstances. We will respond to your Subject Access Request as soon as possible and, in any event, within the statutory 30 days. However, in the event that we need more information from you to verify your identity, which we must do to ensure we disclose your personal data to the right person, the 30 day response period will only commence from the time that we have validated your identity. 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.
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.
This enables you to have any incomplete or inaccurate personal data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
This arises 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.