Privacy Policy

ABOUT PRIVACY POLICY

This privacy policy tells you how SENS uses your personal data when you visit our website, purchase products from us or interact with us online including when you sign up to our newsletter.

The privacy policy has been compiled to better serve those who are concerned with how their 'Personally Identifiable Information' (PII) is being used online. PII, as described in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our website.

HOW WE COLLECT DATA

We collect information from you when you register on our site, place an order, subscribe to a newsletter or enter information on our site.

To be more specific, you may give us data by filling in forms or by corresponding with us by post, phone, email or through chat or social media. This includes data you provide when you:

  • sign up to our newsletter;
  • make enquiries or request information be sent to you;
  • create an account on our website;
  • order our products;
  • engage with us on social media;
  • contact customer support; or
  • leave comments or reviews on our products.

As you interact with us, we may automatically collect data about your device, browsing and patterns. We may also collect data when you click on one of our adverts (including those shown on third party websites or via social media).

We may obtain some data from third parties

We may receive data about you from various categories of third parties, including:

  • from providers of services which facilitate our ecommerce operations, including ecommerce platforms and payment and fraud prevention services;
  • from analytics providers, advertising networks and search information providers; from data partners;
  • from your friends who referred you using ‘refer a friend’;
  • from publicly available sources; and from any third parties who are permitted by law or have your permission to share your personal data with us, such as via social media or review sites.

WHAT PERSONAL DATA WE COLLECT

Personal data, or personal information is 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). Personal data we collect is described in the categories below:

  • Identity Data: first name, last name, date of birth, username or similar identifier and your login/password. If you interact with us through social media, this may include your social media user name.
  • Contact Data: billing address, delivery address, email address and telephone numbers.
  • Financial Data: payment card and direct debit/bank account details.
  • Transaction Data: details about payments to and from you and other details of products and services you have purchased from us.
  • Profile Data: your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses, as well as any profile data which we have added (for example, using analytics and profiling).
  • Technical Data: 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.
  • Usage Data: information about how you use our website, products and services, and any of the content you contribute to the forum.
  • Tracking Data: information we or others collect about you from cookies and similar tracking technologies, such as web beacons, pixels, and mobile identifiers.
  • Marketing and Communications Data: your preferences in receiving direct marketing from us and our third parties and your communication preferences.

We also collect, process and share Aggregated Data (statistical or demographic). 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.

We do not collect any Special Categories of Personal Data (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 share personal data referred to in this category we will not know and can only treat it as personal data.

HOW AND WE USE YOUR PERSONAL INFORMATION

We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:

  • To improve our website in order to better serve you.
  • To quickly process your transactions.
  • To send periodic emails regarding your order or other products and services.

For a more specific explanation of how we use your data, please consult the table below, which explains how use specific data.

PURPOSE OF DATA USE

TYPE OF DATA USED

LEGAL BASIS

Registering a new customer

Identity, Contact

Performance of a contract with you

Managing sales with you, including abandoned baskets on our website

Identity, Contact

Financial, Transaction, Marketing and Communications

Necessary for our legitimate interests (including being able to progress purchases of products by our customers)

Order management, payment collection processing

Identity, Contact

Financial, Transaction, Marketing and Communications

Performance of a contract with you

Necessary for our legitimate interests (including to recover debts due to us)

Managing corporate communications and privacy policy settings

Identity, Contact, Profile, Marketing and Communications

Performance of a contract with you

Necessary to comply with a legal obligation

Necessary for our legitimate interests (to keep our records updated)

Review requests

Identity, Contact, Profile, Marketing and Communications

Necessary for our legitimate interests (to study how customers use our products/services)

Direct marketing delivery

Identity, Contact, Profile, Usage, Marketing and Communications, Technical, Tracking

Necessary for our legitimate interests (to promote our own business and our products and services), unless the law requires that the direct marketing be based on consent

Consent, before we share your personal data with any company outside SENS for their own marketing purposes

Website operation and protection ( troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Identity, Contact, Technical, Tracking

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud)

Necessary to comply with a legal obligation

Content delivery and performance analysis

Identity, Contact, Profile, Usage, Marketing and Communications, Technical

Tracking

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)

Advertisement delivery and analysis

Identity, Contact, Profile, Usage, Marketing and Communications, Technical

Tracking

Necessary for our legitimate interests (to promote our business and products/services, to develop them, to grow our business and to inform our marketing strategy)

Data analysis serving to better our sales tools and offer

Technical, Usage

Necessary for our legitimate interests (to define types of customers for our products/services, to keep our website updated and relevant, to develop our business and to inform our product and marketing strategy)

Promotion of relevant good and services

Identity, Contact, Technical, Usage, Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)

Prevention and detection of criminal action

Identity, Contact, Financial, Transaction, Technical, Tracking

Necessary for our legitimate interests (to protect our business and our customers by way of undertaking fraud monitoring and suspicious transaction monitoring)

Necessary to comply with a legal or contractual obligation to share personal data for the purposes of law enforcement

Business administration, record archivation

All relevant data categories

Necessary to comply with a legal obligation

Necessary for our legitimate interests (to administer our business and keep proper records)

Legal claim resolution

All relevant data categories, depending on the nature of the allegation or claim

Necessary for our legitimate interests (to bring or defend a claim, whether in court proceedings or in an administrative or out of court settlement, for the protection or assertion of our legal rights, your legal rights or the legal rights of others)

FAILURE TO PROVIDE PERSONAL DATA

If you fail to provide personal data, we might not be able to provide you with the desired good services or goods in cases where we need to collect personal data by law, or under the terms of a contract we have with you. In such 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.

ADVERTISING, MARKETING AND COMMUNICATIONS PREFERENCES

There are multiple ways how SENS advertises. While some of them do use personal data, others do not. We might be buying advertising space in the real world and on online platforms, so some of the advertisments you see might not be targetted specifically at you. Some search engines and social media platforms might also assign adverts on the basis of their likelihood to the adverts you displayed previously. This is ruled by the privacy policies of those services.

We might predict the content and good services that you might enjoy on the basis of your previous personal data. You are always able to unsubscribe from any direct marketing communications that we send to you - especially the newsletters. We might also contact you with regards to your abandoned basket that you did not check out in our eshop.

We will get your direct opt-in consent before we share your personal data with any company outside SENS for direct marketing purposes. This is however very unlikely, since we honour your privacy and do not plan to share it with any other companies apart from our service providers.

We also work with partners to try and promote the reach of our adverts and use analytics and retargeting for this reason. We use Tracking Data to deliver relevant online advertising, including on websites and in social media.

Tracking Data (cookies) help us to deliver website and social advertising that we believe is most relevant to you and to potential new SENS customers. The cookies used for this purpose are often placed on our website by specialist organisations – and this is also why when you’ve been on SENS website, you might see content from our website again. This is called retargeting. Cookies can also tell us if you have seen a specific advert, and how long it has been since you have seen it. This is helpful, because it means we can control the effectiveness of our adverts and control the number of times people might be shown our adverts. Cookies also help us understand if you’ve opened a marketing email because we don’t want to send you things you don’t read.

Almost all cookies that relate to advertising are part of third party online advertising networks. If you’d like to read about how you can control which adverts you see online, see opt-out programs established by the European Interactive Digital Advertising Alliance and the Digital Advertising Alliance (United States). We do not control cookies which are set by advertising networks.

Should you wish to opt out of Google retargeting, you can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.

COOKIES

Yes, we use cookies. They are small files that a site or its service provider transfers to your computer's hard drive through your Web browser (if you allow) that enables the site's or service provider's systems to recognize your browser and capture and remember certain information. For instance, we use cookies to help us remember and process the items in your shopping cart. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

We use cookies to:

  • Help remember and process the items in the shopping cart.
  • Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since browser is a little different, look at your browser's Help Menu to learn the correct way to modify your cookies.

If users disable cookies in their browser:

If you turn cookies off, Some of the features that make your site experience more efficient may not function properly.Some of the features that make your site experience more efficient and may not function properly.

Third-party disclosure

We do not sell, trade, or otherwise transfer to outside parties your Personally Identifiable Information.

Third-party links

Occasionally, at our discretion, we may include or offer third-party products or services on our website. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

Google

Google's advertising requirements can be summed up by Google's Advertising Principles. They are put in place to provide a positive experience for users.
https://support.google.com/adwordspolicy/answer/1316548?hl=en

We use Google AdSense Advertising on our website.

Google, as a third-party vendor, uses cookies to serve ads on our site. Google's use of the DART cookie enables it to serve ads to our users based on previous visits to our site and other sites on the Internet. Users may opt-out of the use of the DART cookie by visiting the Google Ad and Content Network privacy policy.

We have implemented the following:

  • Remarketing with Google AdSense
  • Google Display Network Impression Reporting
  • Demographics and Interests Reporting

We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website.

DO NOT TRACK SIGNALS

We honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

It's however important to note that we also allow third-party behavioral tracking.

DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the third parties set out below for the purposes set out in this privacy policy. We may also share your personal data if the law otherwise allows it. These are the categories of parties with whom we might share your data:

  • suppliers and service providers (such as outsourced services partners, technology service providers, manufacturers and post and courier services);
  • payment services providers – payment processors may take your personal data directly from you as part of processing a purchase, and they will be data controllers in their own right for that processing;
  • auditors and professional advisers like bankers, lawyers, accountants and insurers; and
  • government, regulators and law enforcement.

DATA SECURITY

Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible. We utilise relevant security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We also limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. Such parties would always work under confidentiality measures and they would only process your data on our command.

We use regular Malware Scanning.

Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.

We implement a variety of security measures when a user places an order enters, submits, or accesses their information to maintain the safety of your personal information.

All transactions are processed through a gateway provider and are not stored or processed on our servers.

DATA RETENTION

We store your personal data only 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.

To determine the necessary retention period 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.

DATA USE PURPOSE CHANGE

We will always 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 we need to use your personal data for an unrelated purpose, we will contact you and 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.

YOUR LEGAL RIGHTS

You do have rights under data protection laws in relation to your personal data.

  • Request access to your personal data enables you to obtain a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of your personal data allows you to have any incomplete or inaccurate data we hold about you fixed, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data empowers 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, 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 allows you to 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 your personal data 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.
  • Request transfer of your personal data: we have to 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.
  • Right to withdraw consent at any time in 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.

CALIFORNIAONLINCE PRIVACY PROTECTION ACT

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law's reach stretches well beyond California to require any person or company in the United States (and conceivably the world) that operates websites collecting Personally Identifiable Information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals or companies with whom it is being shared. - See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

According to CalOPPA, we agree to the following:

Users can visit our site anonymously.

Once this privacy policy is created, we will add a link to it on our home page or as a minimum, on the first significant page after entering our website.

Our Privacy Policy link includes the word 'Privacy' and can easily be found on the page specified above.

You will be notified of any Privacy Policy changes:

  • On our Privacy Policy Page

Can change your personal information:

  • By logging in to your account

COPPA (Children Online Privacy Protection Act)

When it comes to the collection of personal information from children under the age of 13 years old, the Children's Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States' consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children's privacy and safety online.

We do not specifically market to children under the age of 13 years old.

FAIR INFORMATION PRACTICES

The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.

In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur.

We will notify you via email within 7 business days.

We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.

CAN SPAM ACT

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

To be in accordance with CANSPAM, we agree to the following:

If at any time you would like to unsubscribe from receiving future emails, you can email us at unsubscribe@sensfoods.com and we will promptly remove you from ALL correspondence.

CONTACTING SENS

If there are any questions regarding this privacy policy, you may contact us using the information below.

www.sensbar.com
71-75 Shelton Street, Covent Garden
London, London WC2H9JQ
United Kingdom
hello@sensfoods.com

© 2018 SENS Foods Operations Ltd. | ALL RIGHTS RESERVED