Right to Object: You have a legal right to object at any time to: (i) use of your personal information for direct marketing purposes; and (ii) processing of your personal information which is based on our legitimate interests, unless there are compelling legitimate ground for our continued processing. The security of your personal information is important to Eskimo Joe’s Limited ("us/we/ours").
- AGE REQUIREMENTS
1.1. We do not knowingly collect personal information from children under 18 years of age. If you are under 18 years old, please do not provide any personal information to us. If you are a parent and believe your child under the age of 18 has used the websites and provided personally identifiable information to us, please contact us at the email, phone number and/or address provided below and we will work to delete the relevant account (if applicable) AND any such Personal Information.
- INFORMATION WE MAY COLLECT FROM YOU
2.1. We may collect and process the following information about you:
2.1.1. information that you provide to us when using the Websites, for example including contact information such as name, shipping address, billing address, email address, and telephone number;
2.1.3. information which you provide to us for the purpose of subscribing to direct marketing;
2.1.4. statistical data about your browsing actions and patterns, which does not identify you.
2.2. It is important that the personal information we hold about you is accurate and current. Please keep us informed if, at any time, your personal information changes by contacting us at firstname.lastname@example.org
- HOW WE USE YOUR INFORMATION
3.1. We use information held about you in the following ways:
3.1.1. to administer and provide the Websites to you and to ensure that the Websites are presented in the most effective manner for you and for your computer;
3.1.2. to identify you when you use the Websites;
3.1.3. to process, evaluate and respond to requests, inquiries, complaints and comments made by or about you relating to the Websites;
3.1.4. to improve the Websites;
3.1.5. to manage our communications;
3.1.6. to operate, evaluate and improve our business (including developing new products, services, promotions, deals, and offers);
3.1.7. to keep our Websites and systems secure and prevent fraud;
3.1.8. to monitor and analyse the use of any account to prevent, investigate and report any security incidents or crime;
3.1.9. to improve the functionality and features provided through the Websites and for developing new or additional services, by using user data in an anonymised or pseudonymised form and aggregated form with the anonymised or pseudonymised data of other users of the Websites;
3.1.10. to notify you about changes to our Websites;
3.2. for marketing purposes in accordance with the Marketing section of this Policy, such purposes including:
3.2.1. performing market research;
3.2.2. determining and managing the effectiveness of our advertising, marketing, promotions, deals, and offers;
3.2.3. analysing our products, advertising, marketing, promotions, deals, offers, services and Websites; and
3.2.4. providing, administering and communicating with you about industry news and updates, events, competitions, products, reports, services, promotions, deals, and offers (including by sending you marketing communications where you consent to this);
3.3. where relevant, to meet legal, regulatory and compliance requirements; and
3.4. where relevant, for the establishment, exercise or defence of legal claims.
- THE LEGAL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION
4.1. We will only use your personal information when the law allows us to. We will use your personal information in the following circumstances:
4.1.1. where it is necessary for entering into or performing a contract – in order to perform obligations which arise under the contract we have entered into with you, it will be necessary for us to process your personal data;
4.1.2. where we need to comply with a legal obligation – we are subject to certain legal requirements which may require us to process your personal data. We may also be obliged by law to disclose your personal data to a regulatory body or law enforcement agency;
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 - either we, or a third party, will need to process your personal data for the purposes of our (or a third party's) legitimate interests, provided we have established that those interests are not overridden by your rights and freedoms, including your right to have your personal data protected.
Our legitimate interests include: providing access to and use of the Websites to our users, dealing with user and third party enquiries, keeping our systems secure, improving the functionality of the Websites, informing you of changes to our Websites (or to provide you with updates and other information (including new features)), to help us develop and administer existing and new services, products, promotions, deals, and offers and generally ensuring that our operations are conducted in an appropriate and efficient manner.
4.1.4. where you have provided consent – in some circumstances, we may ask for your consent to process your personal data in a particular way.
- HOW WE SHARE YOUR INFORMATION
We may share your personal information with third parties in the following circumstances:
5.1. for marketing purposes where you consent to this;
5.1.2. to other members of our group of companies, our trusted partners and / or service providers [located within the UK and EEA] for the purpose of: managing or administering certain aspects of the Websites or business; for analytics purposes; and to help us develop new services, products, promotions, deals, and offers. A list of these companies can be found here;
5.1.3. to protect the rights, property or safety of us or other Websites users;
5.1.4. where we are obliged, or permitted, to do so by applicable law, regulation, court order or legal process;
5.1.5. where we are obliged to do so in response to a request by a regulator or law enforcement authority;
5.1.6. in connection with an investigation of suspected or actual illegal activity; or
5.1.7. if we (or all or a portion of our assets) are transferred to or acquired by a third party, in which case personal information held by us about our users may be one of the transferred assets.
5.2. We may pass aggregated information to third parties about how our users use the Websites but this will not include information which could be used to identify you.
- WHERE WE STORE YOUR INFORMATION
6.1. We take appropriate organisational and technical measures to protect your personal information that we hold. We limit access to your personal information to those who we believe reasonably need to come into contact with that information in order to carry out their jobs. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
6.3. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to the Websites and any transmission is at your own risk. 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.
- HOW LONG WE WILL HOLD YOUR INFORMATION
7.1. 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.
7.2. 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.
8.3. All of the major browsers offer tips and guidance for managing the cookies available on your browser. There are also lots of different third-party browser plug ins and extensions available which you can download to make it easier to see and control your cookies.
8.4. You can find out more about internet advertising by visiting the following websites: www.allaboutcookies.org, www.yourchoicesonline.eu, and www.networkadvertising.org. Some of these sites enable you to opt out of online behavioural advertising and other tracking cookies (in addition to the control settings on your browser).
We may from time to time use third party advertisers or sponsors on the Websites. In the event that we do so we will not disclose identifiable information about individuals, but we may provide them with aggregated information about our users. We may also use such aggregated information to help advertisers reach the kind of audience they want to target. We may make use of the personal information we have collected from you to enable us to comply with our advertisers' and sponsors' wishes by displaying their advertisement to that target audience.
- KEEPING YOUR ACCOUNT SECURE
11.1. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Websites, you are responsible for keeping this password confidential and you are responsible for any misuse of such information. You must change your password on a regular basis and must not share your password with anyone.
11.2. You are solely responsible for the security and confidentiality of your account. Please ensure that you do not allow anyone else to access the Website in your name and log off after you have finished accessing your account.
11.3. You are responsible for all orders, and for the accuracy of all information, sent via the internet using your user ID, password or any other personal identification used to identify you on the Websites.
11.4. You will be liable to us for all orders or transactions placed by use of your user ID and password, even if such use might be wrongful. We will not be liable to you for any loss that you may incur as a result of misuse of your user ID and password, and we accept no liability resulting from its unauthorised use, whether fraudulent or otherwise.
12.1. With your permission, we may send you information about other products and services that may be of interest to you where:
12.1.1. you have consented to this (for example where you sign up to our newsletter, via the opt-in box when you register with us through the Websites or elsewhere, via a phone enquiry, submitting a form, creating an account, or placing an order);
12.1.2. you have purchased a product or service from us, unless you have opted-out of receiving such communications; and/or
12.1.3. it is in our legitimate interests to do so.
12.2. You can manage your marketing communication preferences by emailing email@example.com
12.3. You have the right at any time to ask us not to process your personal information for marketing purposes. You can exercise your right to opt out of such processing by checking certain boxes on the forms or registration pages that we use to collect your information, clicking "unsubscribe" links on email communications that we send you. You can also exercise this right at any time by contacting us by post or email at the address set out below.
12.4. Please note that even if you ask not to receive marketing communications, we may still need to send you service messages regarding your use of the Websites.
- RIGHTS THAT YOU HAVE
13.1. You have certain rights in relation to personal information we hold about you. Details of these rights and how to exercise them are set out below. We will require evidence of your identity before we are able to act on your request.
13.1.1. Access - you have the right at any time to ask us for a copy of the personal information that we hold about you and to check that we are lawfully processing it. Where we have good reason, and if the GDPR permits, we can refuse your request for a copy of your personal information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so.
13.1.2. Right of Correction or Completion - if personal information we hold about you is not accurate or is out of date and requires amendment or correction you have a right to have the data rectified or completed. You can let us know by contacting us using the details set out in our Contact section below.
13.1.3. Right of Erasure - in certain circumstances, you have the right to request that personal information we hold about you is erased e.g. if the information is no longer necessary for the purposes for which it was collected or processed or our processing of the information is based on your consent and there are no other legal grounds on which we may process the information.
13.1.4. Right to object to or restrict processing - in certain circumstances, you have the right to object to our processing of your personal information by contacting us using the details set out in our Contact section below. For example, if we are processing your information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests. You also have the right to object to use of your personal information for direct marketing purposes. You may also have the right to restrict our use of your personal information, such as in circumstances where you have challenged the accuracy of the information and during the period where we are verifying its accuracy.
13.1.5. Right of Data Portability - in certain instances, you have a right to receive any personal information that we hold about you in a structured, commonly used and machine-readable format. You can also ask us to transmit that information to you or directly to a third-party organisation. The above right exists only in respect of personal information that you have provided to us previously and is processed by us using automated means. While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third-party organisation's systems. We are also unable to comply with requests that relate to personal information of others without their consent.
13.1.6. Right to withdraw consent - in the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. You can do this by contacting us using the details set out in our Contact section below. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
If you are unhappy about our use of your personal information, you can contact us by using the details in the Contact section below. You are also entitled to lodge a complaint with the UK Information Commissioner's Office using any of the below contact methods:
Telephone: 0303 123 11113
Post: Information Commissioner's Office
- CONTACT US
16.1. If you have any enquires or if you would like to contact us about our processing of your personal information, including to exercise your rights as outlined above, please contact our Data Protection Office using the following details:
Contact Name: Attn: Data Protection Officer
Post: Eskimo Joe’s, Sanderson House Station Road, Horsforth, Leeds, LS18 5NT