We’re committed to safeguarding the privacy of our website users, and below you will find relevant information relating to the collection, storage and processing of any personal data. This privacy notice includes:

• Who we are
• What information do we collect?
• How do we use personal information?
• What legal basis do we have for processing your personal data?
• When do we share personal data?
• Where do we store and process personal data?
• Ho do we secure personal data?
• Your rights in relation to personal data
• How to contact Us
• This notice applies to our website users, email subscribers and customers within but not limited to the capacity as a customer, subscriber and visitor.

 

Please feel free to read through the below information in detail, and drop us a line on hello@honestly-good.co should you have any questions!

 

Who we are?

Our Data Controller is:

Smooth Organics Ltd 78 Graham Gardens, Luton, Bedfordshire LU3 1NQ. The controller’s representative is Vikesh Kotecha (Director) and their contact details are: vikesh@honestly-good.co

 

What information do we collect?

Specify the types of personal information you collect, eg names, addresses, user names, etc. You should include specific details on:

• We collect data in the following ways:
• Through subscription purchase: name, email address, phone number, billing address, delivery address, as well as product specific preferences such as subscription frequency, box preference and size preference. This is captured through our checkout process.
• Via our mailing list email capture form: name and email address to subscribe to our regular newsletters. We will collect your name, email address and the method and date by which you subscribed (e.g. footer email form, £10 off email form, blog article email form).
• Competition entry: We will record your name, email address, phone number and smoothie idea, as well as date and location of the competition
• All data will be used to improve our products and services, and will be stored on our chosen email client (ActiveCampaign) and may be sorted, tagged and segmented in compliance with GDPR.

How do we use personal information?

• personalisation of content, business information or user experience
• account set up and administration
• delivering marketing and events communication
• carrying out polls and surveys
• internal research and development purposes
• providing goods and services
• legal obligations (eg prevention of fraud)
• meeting internal audit requirements

 

 

What legal basis do we have for processing your personal data?

The following conditions within GDPR are applicable to the processing of your information:

• consent – We will ask for explicit consent to any marketing material in the email capture form. You will be able to unsubscribe from marketing material any time using the “unsubscribe” link the footer of any email received from The Honestly Good Smoothie Co.
• contract – As part of the contract between customer and Smooth Organics Ltd to provide delivery of goods and services paid for, we will be required to process transaction related information including but not limited to name, delivery address, delivery instructions, phone number and email address. Payment information will be processed by our third party payment gateway provider Stripe.

 

 

When do we share personal data?

We may share personal data about you:

1. with third parties who are directly involved in dealing with any request or enquiry made by you;
2. where such disclosure is required by law;
3. with third parties who are providing us with professional advice;
4. where the disclosure is in connection with any criminal investigation, legal proceedings or prospective legal proceedings where permitted by law;
5. where the disclosure is in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
6. where we are required to enforce our Terms and Conditions of Sale or our Terms of Use; or
7. where we have stated or informed you otherwise (e.g. in this policy or on our website).

We will not pass on your information to any third party for the purpose of marketing.

We may also disclose your personal data to third parties in the event that we sell or buy any business or assets (in which case we may disclose your personal data to the prospective seller or buyer of such business or assets) or if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our clients and subscribers will be one of the transferred assets.

 

Where do we store and process personal data?

We only retain your personal data for as long as we need it for the purpose for which is was collected. Whilst taking in to consideration our legal obligations, we will on an ongoing basis: review the length of time we retain your personal data; consider the purpose or purposes for which we hold your personal data for in deciding whether (and for how long) to retain it; securely delete your personal data if it is no longer needed for such purpose or purposes; and update, archive or securely delete your personal data if it goes out of date.

How do we secure personal data?

We will take all reasonable steps to protect your personal data. However, the Internet is global and no data transmitted via the Internet can be guaranteed by us to be completely secure during transmission. We cannot guarantee the security of any data that you disclose online and we will not be responsible for any breach of security unless this is due to our negligence or wilful default.

Our website is hosted in the UK and all data provided to us is stored within our servers located in the UK or the European Economic Area (“EEA”). Sometimes we may need to transfer personal data we collect from you to third-party data processors in countries that are outside the EEA – for example, this might be required in order to fulfil your order, process your payment details or provide support services. If we do this, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

1. The transfer is to a third party located in a country that has been deemed to provide an adequate level of protection for personal data by the European Commission.
2. The transfer is subject to use of a contract approved by the European Commission which gives personal data the same protection it has in Europe.
3. The transfer is to a third party based in the US which is part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

In the absence of an adequacy decision in respect of the relevant country, or appropriate safeguards as detailed above, we will not transfer your personal data outside of the EEA unless we have a lawful basis for doing so (for example, because you have explicitly consented to the proposed transfer).

Your rights in relation to personal data

If we are sending marketing materials to you by any means, you may ask us to stop sending such marketing materials at any time. Please see section 6 above for further information on how to do this.

You have a legal right to see a copy of the personal data that we keep about you, subject to certain exemptions. Requests for such information should be made by email to vikesh@honestly-good.co .

In some circumstances you may also have a right to:

1. rectify or erase any personal data we hold about you;
2. restrict our processing of your personal data;
3. object to us processing your personal data (for example, where we are processing your personal data based on our legitimate interests, you can ask us to stop processing your personal data. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data);
4. data portability in respect of your personal data.

In accordance with applicable data protection legislation, we follow security procedures when we process your personal data. We may therefore request proof of your identity before disclosing certain information to you or acting on any requests pursuant to this section 8.

Please contact us at the above address if you have any reason to believe that information we hold about you is inaccurate.

 

How to contact us?

Should you wish to contact us in relation to the privacy and security of your data, please feel free to contact:

Smooth Organics Ltd, 78 Graham Gardens, Luton, Bedfordshire, LU3 1NQ

vikesh@honestly-good.co