Privacy Policy

Welcome to Our Privacy Policy
We highly value your privacy and are dedicated to safeguarding your personal information.
This privacy policy outlines how we manage your personal data when you visit our website,
irrespective of your location, and elucidates your privacy rights along with legal protections.

Contents

1. Essential Information and Our Identity 
2. Data Collection 
3. Data Collection Methods 
4. Data Usage 
5. Disclosure of Your Personal Data 
6. International Transfers 
7. Data Security 
8. Data Retention 
9. Your Legal Rights 
10. Cookies 
11. Glossary 

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1. Essential Information and Our Identity
Purpose of this Privacy Policy: This policy aims to provide you with insights into how we
gather and handle your personal data when you engage with our website. This includes any
data you furnish while signing up for our newsletter, purchasing products/services, or
participating in competitions. Our website does not target children, and we do not knowingly
collect their data.
Controller: Francesca Grace Muirhead (referred to as “we”, “us” or “our” in this privacy
policy). is the controller responsible for your personal data. For any inquiries regarding this
policy or our privacy practices, please contact us via the details provided below:
Francesca Grace Muirhead
mcleodfrancesca@gmail.com
16 St Aubyns Road, Brighton, BN41 1AD
Tel: 07756250333
You retain the right to lodge a complaint with the Information Commissioner’s Office (ICO),
the UK supervisory authority for data protection issues, although we encourage you to reach
out to us initially to address your concerns.

Updates to the Privacy Policy and Your Obligations to Inform Us of Changes: We
regularly review our privacy policy. The latest version was updated on 21 st April 2024. It's
vital to keep us informed about any changes to your personal data during your association
with us to ensure its accuracy and currency.
Third-Party Links: Our website may contain links to third-party websites. Clicking on these
links may enable third parties to gather or share data about you. We do not govern these
third-party websites and are not liable for their privacy practices. We recommend reviewing
the privacy policies of every website you visit upon leaving ours.

2. Data Collection
We collect various types of personal data to enhance your website experience. These
include:
Identity Data - includes first name, last name, username or similar identifier and title.

• 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 this 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.

We also gather Aggregated Data for statistical or demographic purposes. While this data
may be derived from your personal data, it does not reveal your identity directly or indirectly.
We do not collect Special Categories of Personal Data or information regarding criminal
convictions 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.

Failure to Provide Personal Data: 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.

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3. Data Collection Methods
Direct interactions. 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:
• apply for our products or services;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us.
Automated technologies or interactions. As you interact with our website, we will
automatically collect Technical Data about your equipment, browsing actions and patterns.
We collect this personal data by using cookies[server logs] and other similar technologies.
[We may also receive Technical Data about you if you visit other websites employing our
cookies.] Please see our cookie policy [LINK] for further details.
Third parties or publicly available sources. We will receive personal data about you from
various third parties [and public sources] as set out below:
• Technical Data from the following parties:
(a) analytics providers such as Google based outside the EU;
(b) advertising networks based inside or outside the EU; and
(c) search information providers Google based inside or outside the EU.
• Contact, Financial and Transaction Data from providers of technical, payment and
delivery services based inside outside the EU.
• Identity and Contact Data from data brokers or aggregators based inside or outside the
EU.
• Identity and Contact Data from publicly available sources such as Companies House
and the Electoral Register based inside the EU.

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4. Data Usage
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:
• 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 obligation”.
Please see the Glossary below for the meaning of these terms.
Generally, we do not rely on consent as a legal basis for processing your personal data
although we will get your consent before sending third party direct marketing
communications to you via email or text message. You have the right to withdraw consent to
marketing at any time by contacting us.

Purposes for Using Your Personal Data:
We have set out below 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.
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 and Lawful basis for processing including basis of
legitimate interest
To register you as a new customer:
Type of data: (a) Identity, (b) Contact
Lawful basis: (a) Performance of a contract with you.
To process and deliver your order including: (a) Manage payments, fees and charges; (b)
Collect and recover money owed to us
Type of data: (a) Identity; (b) Contact; (c) Financial; (d) Transaction; (e) Marketing and
Communications.
Lawful basis: (a) Performance of a contract with you; (b) Necessary for our legitimate
interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to
our terms or privacy policy; (b) Asking you to leave a review or take a survey

Type of data: (a) Identity; (b) Contact; (c) Profile; (d) Marketing and Communications
Lawful basis: (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 and to
study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey
Type of data: (a) Identity; (b) Contact; (c) Profile; (d) Usage; (e) Marketing and
Communications
Lawful basis: (a) Performance of a contract with you; (b) Necessary for our legitimate
interests (to study how customers use our products/services, to develop them and grow our
business). 
To administer and protect our business and this website (including troubleshooting, data
analysis, testing, system maintenance, support, reporting and hosting of data)
Type of data: (a) Identity; (b) Contact; (c) Technical
Lawful basis: (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 deliver relevant website content and advertisements to you and measure or understand
the effectiveness of the advertising we serve to you
Type of data: (a) Identity; (b) Contact; (c) Profile; (d) Usage; (e) Marketing and
Communications; (f) Technical
Lawful basis: Necessary for our legitimate interests (to study how customers use our
products/services, to develop them, to grow our business and to inform our marketing
strategy)
To use data analytics to improve our website, products/services, marketing, customer
relationships and experiences
Type of data: (a) Technical; (b) Usage

 Lawful basis: 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
Type of data: (a) Identity; (b) Contact (c) Technical; (d) Usage; (e) Profile; (f) Marketing and
Communications
Lawful basis: Necessary for our legitimate interests (to develop our products/services and
grow our business)
Marketing
We offer choices regarding certain personal data uses, particularly in marketing and
advertising. You may receive marketing communications from us unless you opt out.
Promotional Offers from Us
We may use your Identity, Contact, Technical, Usage and Profile 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).
You will receive marketing communications from us if you have requested information from
us or purchased goods or services from us and you have not opted out of receiving that
marketing.
Third-Party Marketing
We will get your express opt-in consent before we share your personal data with any third
party for marketing purposes.
Opting Out
You can ask us or third parties to stop sending you marketing messages at any time by
contacting us 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. For more information
about the cookies we use, please see our cookies policy.
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 contact us.

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.

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5. Disclosure of Your Personal Data
We may share your personal data with the parties set out below for the purposes set out in
the table in section 4 above.
• Third Parties as listed in the Glossary below.
• 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 policy.
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
We do not transfer your personal data outside the European Economic Area (EEA).

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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 reasonably necessary to fulfil the
purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax,
accounting or reporting requirements. We may retain your personal data for a longer period
in the event of a complaint or if we reasonably believe there is a prospect of litigation in
respect to our relationship with you.
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,
regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see your legal rights in section 9
below for further information.
In some circumstances we will 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
Under certain circumstances, you have rights under data protection laws in relation to your
personal data. Please refer to the Glossary to find out more about these rights:
• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
Under certain circumstances, you have rights under data protection laws in relation to your
personal data. Please refer to the Glossary to find out more about these rights:
• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.

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10. Cookies
Our website uses cookies to distinguish you from other users of our website. This helps us to
provide you with a good experience when you browse our website and also allows us to
improve our site. By continuing to browse the site, you are agreeing to our use of cookies.
A cookie is a small file of letters and numbers that we store on your browser or the hard
drive of your computer if you agree. Cookies contain information that is transferred to your
computer’s hard drive.
We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our
website. They include, for example, cookies that enable you to log into secure areas of our
website, use a shopping cart or make use of e-billing services.
• Analytical/performance cookies. They allow us to recognise and count the number of
visitors and to see how visitors move around our website when they are using it. This helps
us to improve the way our website works, for example, by ensuring that users are finding
what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our
website. This enables us to personalise our content for you, greet you by name and
remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have
visited and the links you have followed. We will use this information to make our website and
the advertising displayed on it more relevant to your interests. We may also share this
information with third parties for this purpose.
Please note that third parties (including, for example, advertising networks and providers of
external services like web traffic analysis services) may also use cookies, over which we
have no control. These cookies are likely to be analytical/performance cookies or targeting
cookies
You block cookies by activating the setting on your browser that allows you to refuse the
setting of all or some cookies. However, if you use your browser settings to block all cookies
(including essential cookies) you may not be able to access all or parts of our site.

11. Glossary
LAWFUL BASIS
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.
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.
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.
THIRD PARTIES
• Service providers based in the UK who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers,
bankers, auditors and insurers based in the UK who provide consultancy, banking, legal,
insurance and accounting services.

• HM Revenue & Customs, regulators and other authorities acting as processors or joint
controllers based in the UK who require reporting of processing activities in certain
circumstances.
YOUR LEGAL RIGHTS
You have the right to:
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.
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.
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.
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.
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:
• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• 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.
• You have objected to our use of your data but we need to verify whether we have
overriding legitimate grounds to use it.
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.
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.