Privacy Policy

PURE BIO LIMITED Privacy policy

Your privacy is very important to us. Accordingly, we have developed this Policy in order for you to understand how we collect, use, communicate and disclose and make use of personal information.

This is the Privacy Policy of PURE BIO LTD

We respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from). We’ll also tell you about your privacy rights and how the data protection law protects you.

1. WHO WE ARE AND IMPORTANT INFORMATION 

What is the purpose of this privacy notice?

This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you   purchase a product or subscribe to our Practitioner newsletter or leave feedback on our contact form.

This website is not intended for children and we do not knowingly collect data relating to children.

You must read this privacy notice together with any other privacy 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.

Data controller

PURE BIO LTD is the controller and responsible for your personal data (collectively referred to as, "we", "us" or "our" in this privacy notice). Our contact details are Pure Bio Ltd, Ground Floor, 44 Springfield Road, Horsham West Sussex RH12 2PD. Email info@purebio.co.uk Telephone 01403 730342. Our Registered office is Cornelius House, 178/180 Church Road, Hove, East Sussex BN3 2DJ. For all data matters contact The Data Protection officer at Pure Bio Ltd by emailing us at info@purebio.co.uk

Third-party links outside of our control

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 PERSONAL DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.

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

• Identity Data includes name, title.
• Contact Data includes billing address/delivery address/email address/ telephone numbers.
• Financial Data includes credit card/payment card details
• Transaction Data includes details of products & services you have purchased from us and payments made to and from you.
• Technical Data includes your IP address and browser type, location, operating system and other similar information.
• Marketing & communications Data includes your preferences in receiving marketing from us & your communication preferences.

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.

If you fail to provide personal data

Where we need to collect your 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.

3. HOW WE COLLECT YOUR PERSONAL DATA

We use different methods to collect data from and about you including through:

• Directly. You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you :
  • Purchase our products or services
  • Create an account on our website
  • Subscribe to our Practitioner newsletter
  • Request marketing to be sent to you
  • Register with Pure Bio as a qualified Practitioner
  • Request your Practitioner details to be listed on our website directory
• Web Browser cookies. 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. Cookies are small pieces of text information that ask your computer permission to allow placement on your hard drive. Cookies do not provide us access to your computer or any information other than that which you have chosen to share with us. We use cookies on our website to analyse visitor traffic.

4. HOW WE USE YOUR PERSONAL DATA

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:

• Performance of Contract this 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.

• Legitimate Interest this means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the 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).

• Comply with a legal or regulatory obligation this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or post. You have the right to withdraw consent to marketing at any time by contacting us at info@purebio.co.uk .

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, with the legal bases we rely on to do so.

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 at info@purebio.co.uk 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 or practitioner	(a) Identity (b) Contact		Performance of a contract with you
To process and deliver your order including:		(a) Identity	(a) Performance of a contract with you
(a) Manage payments, fees and charges		(b) Contact	(b) Necessary for our legitimate interests (to recover debts due to us)
		(c) Financial
(b) Process practitioner discounts    & commissions
(c) Collect and recover money owed to us		(d) Transaction
To manage our relationship with you which will include:		(a) Identity	(a) Performance of a contract with you
		(b) Contact	(b) Necessary to comply with a legal obligation
(a) Notifying you about changes to our terms or privacy policy
			(c) Necessary for our legitimate interests (to keep our internal records updated and to study how customers use our Products & services)
(b) Asking you to leave feedback or take a survey		(c) Marketing and Communications
To administer and protect our business and this website		Identity	(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) Contact
(including troubleshooting, data analysis, testing, System maintenance, support, reporting and hosting of data)
		(c) Technical
			(b) Necessary to comply with a legal obligation
To improve our website, products & services, customer service, & marketing.		Identity	Necessary for our legitimate interests (to keep our website updated, to study how customers use our products and services, to develop them, to grow our business and to inform our marketing  strategy).
(including sending you practitioner Newsletters containing product updates, special offers and information on events & seminars via email or post, provided you have ‘opted in’.)		(b) Contact
		(c) Technical
		(d) Marketing  &  communications

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We have established the following personal data control mechanisms:

Third-party marketing

We do not share your personal data with any company outside of Pure Bio Ltd for their direct marketing purposes.

Opting out

You can ask us 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 info@purebio.co.uk  at any time.

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/service purchase, or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Change of purpose

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 us at info@purebio.co.uk .

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.

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. WHO WE SHARE YOUR PERSONAL DATA WITH

We may have to share your personal data with external Third Parties Service providers to help us operate our business or administer activities on our behalf for the purposes set out in the table in paragraph 4 above. For example these parties may include:

• Professional advisers including lawyers, bankers, auditors and insurers based in the UK who provide banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom who  may require reporting of processing activities in certain circumstances.
• Mail Chimp is used as our email marketing automation platform to process your email information in order to distribute our monthly practitioner newsletters. The software is fully GDPR compliant, see link for more details

https://kb.mailchimp.com/accounts/management/about-mailchimp-the-eu-swiss-privacy-shield-and-the-gdpr

• PayPal and WorldPay are used to process payments for any products purchased. Neither us, PayPal nor World pay retain any financial information you may submit as part of the purchasing process. Your data is encrypted before transmission to prevent misuse of the data by third parties and is transmitted over a SSL (secure socket layer) channel.
• 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.

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

 Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by implementing safeguards:

• Any sensitive and private data exchange (e.g. the processing of a card payment) happens over a (SSL) secured communication channel and is encrypted and protected with digital signatures.
• Any processing of email marketing data is undertaken by third party providers who comply with the GDPR regulations or a similar framework e.g. EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework.

7. DATA 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. DATA RETENTION

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. We continually review what information we hold, and delete what is no longer required.

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.

By law we have to keep basic information about our customers (including contact, identity, financial and transaction data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

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

Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:

• The right to request a copy of the personal data which we hold about you;
• The right to request that we correct any personal data if it is found to be inaccurate or out of date;
• The right to request your personal data is erased where it is no longer necessary to retain such data;
• The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
• The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable (i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means);
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
• The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).

If you wish to exercise any of the rights set out above, please contact us in writing addressed to Pure Bio Ltd, Ground Floor, 44 Springfield Road, Horsham, West Sussex, RH12 2PD

No fee required – with some exceptions

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 admin 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 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.

Time limit to respond

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. Changes to this notice and your duty to inform us of changes

Pure Bio Ltd has the discretion to update this privacy policy at any time. This version of our privacy policy was last updated on 25^th May 2018.

Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.

11. Queries, requests or concerns

To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact us at

PURE BIO LTD, GROUND FLOOR, 44 SPRINGFIELD ROAD, HORSHAM, WEST SUSSEX, RH12 2PD

 info@purebio.co.uk  or Tel: 01403 730342

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK.