GDPR Policy Statement

PURPOSE OF THIS PRIVACY POLICY

We are committed to protecting your personal information and to being transparent about the information we hold about you. Using personal information allows us to develop a better understanding of our customers, and in turn to provide you with relevant and timely information about Rozalex and our products.

The purpose of this policy is to give you a clear explanation about how we collect and process your personal information through your use of our website, including any data you may provide through this website and when you sign up to our newsletter and purchase online.

This privacy policy may change from time to time. We will always communicate any changes to you, where we have accurate contact details.

It is important that you read this privacy policy when we are collecting or processing personal information about you, so that you are aware of how and why we are using your personal information.

Please visit this section of our website periodically in order to keep up to date with changes in our privacy policy.

We will use the information that we collect about you in accordance with:

• The Data Protection Act 1998
• The Privacy and Electronic Communications (EC Directive) Regulations 2003
• The EU General Data Protection Regulation (Regulation EU 2016/679), (‘GDPR’) which becomes effective from 25 May 2018

This policy explains:

• Who we are
• Information we may collect about you
• How we collect your data
• How we may use your information
• Disclosure of your details to third parties
• Security of your personal information
• Data retention
• Your legal rights
• Contact details and further information

If you have any questions, please contact the Data Controller at Rozalex by writing to the below contact details:

Rozalex Data Controller

P.O. Box 17659

Henley-in-Arden,

Warwickshire,

B95 8BP

United Kingdom.

1. ABOUT US

Rozalex is a trading name of Hughen Limited, a UK based, manufacturer and distributor of professional hand care products registered in England and Wales, number 07995212

2. INFORMATION WE MAY COLLECT ABOUT YOU

Personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed, i.e. anonymous data.

We may collect, use, store and transfer different kinds of personal information about you which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your 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 our website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. This also includes us making a note of conversations we have had with you in person and/or communications you sent to Rozalex. This helps us to manage our relationship with you and ensures you only receive relevant and timely communications from us.

3. HOW WE COLLECT YOUR DATA

We collect different information about you in a number of ways:

Information you give us

When you create an account on our website, buyproducts, sign up to our newsletter, request marketing materials or give us feedback, we will store the personal information you give to us such as your name, email address, postal address, telephone number and card details. We will also keep a record of your purchases.

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 and other similar technologies.

Information from third parties

We occasionally receive information about you from third parties as set out below:

• Analytics providers such as Google
• Advertising networks such as Facebook
• Search information providers such as Google AdWords

4. HOW WE MAY USE YOUR INFORMATION

We will only use your personal information when the law allows us to.

Most commonly, we will use your personal information in the following ways:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• 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.
• Where we need to comply with a legal or regulatory obligation.
• Where we have your explicit consent before using your personal information in that specific situation. However, generally we do not rely on consent as a legal basis for processing your personal information and you have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal information

We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

 Marketing communications

We aim to communicate with you about the products, services and events that you find relevant, timely, and never excessive. To do this, we use data that we have stored about you, such as which products you have purchased in the past, as well as any contact preferences you may have told us about.

We use our legitimate organisational interest as the legal basis for communications by post and email. In the case of postal mailings, you may opt-out of receiving these at any time using the contact details at the end of this policy or by updating your contact preferences in your online account with us.

In the case of email, we will give you an opportunity to opt out of receiving electronic communications by including an ‘unsubscribe’ link in every e-mail we send you. Alternatively, you can use the contact details at the end of this policy.

As part of our service to you, we may contact you by email or telephone to provide essential information related to your purchase and visit.

5. DISCLOSURE OF YOUR DETAILS TO THIRD PARTIES

There are certain circumstances under which we may disclose your personal information to third parties. These are as follows:

• To our service providers who process data on our behalf and on our instructions . We require all third parties to respect the privacy of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
• Where we are under a duty to disclose your personal information in order to comply with any legal obligation (for example to government bodies and law enforcement agencies).

We do not sell personal details to third parties for any purpose.

6. SECURITY OF YOUR PERSONAL INFORMATION

We have put in place appropriate safeguards (both in terms of our procedures and the technology we use) to keep your personal information as secure as possible. Third parties will also be subject to a duty of confidentiality.

We will not transfer, process or store your data anywhere that is outside of the European Economic Area, unless we have a contractual agreement in place that is of an equivalent standard to GDPR.

7. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including to satisfy 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.

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfillment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. Rozalex will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

8. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal information, as follows:-

1. a) Request access to your personal information

You have a right to request a copy of the personal information that we hold about you. Please use the contact details at the end of this policy if you would like to exercise this right, or any of the rights listed below.  If you are a European citizen and consider our use of your personal information to be unlawful, you have the right to lodge a complaint with the UK’s supervisory authority, i.e. the Information Commissioner’s Office.

1. b) Request correction of your personal information

You have the right to request that we correct the personal information we hold about you, although we may need to verify the accuracy of the new information you provide to us.

1. c) Request erasure of your personal information

You have the right to request that we delete or remove personal information where there is no good reason for us continuing to process it. Please note that we may not always be able to comply with your request for erasure if there are specific legal reasons- which will be notified to you at the time of your request.

1. d) Object to processing of your personal information

You have the right to object to the 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.

1. e) Request restriction of processing your personal information

You have the right to request that we 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.

1. f) Request transfer of your personal information

You have the right to request that the personal information we hold about you is transferred to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Please 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.

1. g) Right to withdraw consent

In circumstances where we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time. 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.

Please also note the following:-

No fee usually required

You will not have to pay a fee to access your personal information (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.

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 information (or to exercise any of your other rights). This is a security measure to ensure that personal information 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 two months. Occasionally it may take us longer than a month if your request is particularly complex or you have made a nomber of requests. In this case, we will notify you and keep you updated.

9. CONTACT DETAILS AND FURTHER INFORMATION

Please get in touch with us if you have any questions about any aspect of this privacy policy, and in particular if you would like to object to any processing of your personal information that we carry out for our legitimate organisational interests.

Please also contact us if you have any questions about the information we hold about you, or to change your contact preferences with us:

Email us: info@rozalex.co.uk

Write to us:

Rozalex Data Controller

P.O. Box 17659

Henley-in-Arden,

Warwickshire,

B95 8BP

United Kingdom