Calla Lily Personal Care Ltd 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 www.calla.ly, 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 layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURES OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
1. IMPORTANT INFORMATION AND WHO WE ARE
1.1 Purpose of this privacy notice
1.1.1 This privacy notice aims to give you information on how Calla Lily Personal Care Ltd collects and processes your personal data through your use of this website, including any data you may provide through our website when you sign up to receive our marketing mailings, purchase a product or take part in a competition.
1.1.2 This website is not intended for children and we do not knowingly collect data relating to children.
1.1.3 It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
1.2.1 Calla Lily Personal Care Ltd (a company incorporated and registered in England and Wales with company number 03502936) is the controller and responsible for your personal data (collectively referred to as the “Company, “we”, “us” or “our” in this privacy notice).
1.2.2 If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.
Email address: email@example.com
Postal address: Calla Lily Personal Ltd, 10 Rose & Crown Yard, King Street, London, SW1Y 6RE.
Telephone number: +44 207 879 8717
1.2.3 You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
1.3 Your duty to inform us of changes
1.3.1 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.
1.4 Third-party links
1.4.1 This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
2.1 Personal data, or 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 (anonymous data).
2.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
2.2.1 Identity Data includes your first name, last name, marital status, title, date of birth, gender, college or university, graduation year, username, referral code or similar identifier.
2.2.2 Contact Data includes your billing address, delivery address, email address and telephone numbers.
2.2.3 Financial Data includes your payment card details (including Paypal details) and your ongoing revenue and credit balances.
2.2.4 Transaction Data includes details about payments to and from you and other details of products you have purchased from us.
2.2.5 Technical Data includes your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, language settings, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
2.2.6 Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, previous period products used and how you found out about us (including the name and email of the customer who referred you), number of customers who have successfully used your unique referral link, feedback, reviews and survey responses.
2.2.7 Usage Data includes information about how you use our website (including website pages viewed and when they were visited) and engage with email communications sent to you by us e.g. when you open our emails. This also includes information you provide to us via live chat on our website or email relating to queries you may have regarding our products and/or services.
2.2.8 Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
2.3 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.
2.4 Unless you voluntarily provide it to us, 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.
2.5 If you fail to provide personal data
2.5.1 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.
2.6 Payments by Klarna. In order to offer you Klarna’s payment methods, we might in the checkout pass your personal data in the form of contact and order details to Klarna, in order for Klarna to assess whether you qualify for their payment methods and to tailor those payment methods for you. Your personal data transferred is processed in line with Klarna’s own privacy notice.
3. HOW IS YOUR PERSONAL DATA COLLECTED
3.1 We use different methods to collect data from and about you including through:
3.1.1 Direct interactions. You may give us your Identity Data, Contact Data, Financial Data, Profile Data, Usage Data and Marketing and Communications Data by filling in forms and answering questions that we pose to you on our website or by corresponding with us by post, phone, email, live chat or otherwise. This includes personal data you provide when you:
188.8.131.52 purchase our products (including updates to your subscription plan);
184.108.40.206 create an account and/or edit your details on our website (including adding to your customer profile);
220.127.116.11 sign up to our mailing list;
18.104.22.168 refer a friend;
22.214.171.124 complete a survey; or
126.96.36.199 give us feedback or a review.
3.1.2 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 cookies, web beacons and other similar technologies. Please see our cookies policy for further details.
3.1.3 Third parties or publicly available sources. We may receive personal data about you from third parties as set out below:
188.8.131.52 Identity Data, Contact Data, Profile Data, Usage Data and Marketing and Communications Data from our providers of survey and form creation tools, email marketing and customer engagement services.
184.108.40.206 Identity Data, Contact Data, Financial Data and Transaction Data from our providers of payment and delivery services.
220.127.116.11 Technical Data from providers of our website analytics services.
18.104.22.168 Identity Data and Contact Data from publicly available sources such as social media platforms, LinkedIn and public websites.
4. HOW WE USE YOUR PERSONAL DATA
4.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
4.1.1 Where you have consented to our use of your personal data. You have the right to withdraw such consent at any time by contacting us.
4.1.2 Where we need to perform the contract we are about to enter into or have entered into with you.
4.1.3 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.
4.1.4 Where we need to comply with a legal or regulatory obligation.
4.2 Purposes for which we will use your personal data
4.2.1 We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
4.2.2 Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||(a) Identity Data
(b) Contact Data
|(a) Performance of a contract with you
|To process and deliver your orders including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(c) Verify your student status
|(a) Identity Data
(b) Contact Data
(c) Financial Data
(d) Transaction Data
(e) Marketing and Communications Data
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
(c) Necessary to comply with a legal obligation
|To manage our relationship with you which will include:
(a) Notifying you about changes to our terms, privacy notice or any other of our policies
(b) Asking you to leave a review or take a survey and posting such review/survey response on our website
(c) Providing you with unique referral links to provide to your contracts
(d) Providing you with notifications regarding your subscriptions
|(a) Identity Data
(b) Contact Data
(c) Marketing and Communications Data
(d) Profile Data
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated; to study how customers use our products/services including understanding demographic and customer purchasing habits); to associate referred customers to the customers who referred them; to calculate referral statistics; to inform the development and improvement of our products
(d) You have provided your consent
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity Data
(b) Contact Data
(c) Technical Data
(d) Usage Data
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical Data
(b) Usage Data
|(a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity Data
(b) Contact Data
(c) Technical Data
(d) Usage Data
(e) Profile Data
(f) Marketing and Communications Data
|(a) Necessary for our legitimate interests (to develop our products/services and grow our business)
(b) You have provided your consent
4.3.1 We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
4.4 Promotional offers from us
4.1.1 We may use your Identity Data, Contact Data, Technical Data, Usage Data, Profile Data and Marketing and Communications 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 (we call this marketing).
4.4.2 You will receive marketing communications from us if you have requested information from us or purchased goods from us or if you provided us with your details when you registered for a promotion and, in each case, you have not opted out of receiving that marketing.
4.5 Third-party marketing
4.5.1 We will get your express opt-in consent before we share your personal data with any company other than Calla Lily Personal Care Ltd for marketing purposes.
4.6.1 You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
4.6.2 Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase, product experience or other transactions.
4.8 Change of purpose
4.8.1 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.
4.8.2 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.
4.8.3 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.
5. DISCLOSURES OF YOUR PERSONAL DATA
5.1 We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4.2.2 above.
5.1.1 External Third Parties as set out in the glossary to this privacy notice.
5.1.2 Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
5.2 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
6.1 Some of our External Third Parties are based or process data outside the European Economic Area (EEA) so the processing of your personal data will involve a transfer of data outside the EEA.
6.2 Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
6.2.1 We will transfer your personal data to a country that has been deemed to provide an adequate level of protection for personal data by the European Commission.
6.2.2 Where we use a service provider, we may use specific contracts approved by the European Commission which give your personal data the same protection it has in Europe.
6.2.3 If we use a service provider based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
6.3 Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. DATA SECURITY
7.1 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.
7.2 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. DATA RETENTION
8.1 How long will you use my personal data for?
8.1.1 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.
8.1.2 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.
8.1.3 By law we have to keep basic information about our customers (including Contact Data, Identity Data, Financial Data and Transaction Data) for six years after they cease being customers for tax purposes.
8.1.4 In some circumstances you can ask us to delete your data: see Request erasure below for further information.
8.1.5 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.
9. YOUR LEGAL RIGHTS
9.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data as set out below:
9.1.1 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.
9.1.2 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.
9.1.3 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.
9.1.4 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.
9.1.5 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.
9.1.6 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.
9.1.7 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.
9.2 If you wish to exercise any of the rights set out above, please contact us.
9.3 No fee usually required
9.3.1 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.
9.4 What we may need from you
9.4.1 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.
9.5 Time limit to respond
9.5.1 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.
10.1 Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
10.2 External Third Parties means:
10.2.1 Service providers acting as data processors who provide us with payment processing, IT and system administration services.
10.2.2 Service providers acting as data processors who provide us with form/survey creation, email marketing, customer engagement, inventory and accounting software tools and project management services.
10.2.3 Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
10.2.4 HM Revenue & Customs and other authorities who require reporting of processing activities in certain circumstances.
10.3 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.
10.4 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.