Privacy Policy

Introduction 

Welcome to Paloma's Products privacy policy. This Privacy Policy describes how your personal information is collected, used, and shared when you visit or make a purchase from palomasproducts.co.uk (the “Site”).

Paloma’s Products respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.  

Please  use the Glossary to understand the meaning of some of the terms used in this privacy policy. 

Important information and who we are 

Purpose of this privacy policy 

This privacy policy aims to give you information on how Paloma's Products collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter OR purchase a product or service OR take part in a competition  

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

It is important that you read this privacy policy together with any other privacy policy or fair processing policy 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 policy supplements other notices and privacy policies and is not intended to override them.  

Paloma’s Products Limited is the controller and responsible for your personal data (collectively referred to as "COMPANY", "we", "us" or "our" in this privacy policy). 

Contact details 

If you have any questions about this privacy policy or our privacy practices, please contact Paloma's Products via email: 

hello@palomasproducts.co.uk 

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.  

Changes to the privacy policy and your duty to inform us of changes 

We keep our privacy policy under regular review and may change it from time to time, in order to reflect for example, changes to our practices or for other operational, legal or regulatory reasons. This version was last updated on 15/11/2022. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. 

Third-party links

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 policy of every website you visit.

1. The data we collect about you and how we collect it 

Personal data, or personal information, means 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). 

When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.” 

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

- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org. 

This website is powered by Shopify, you can read their cookie policy here

- “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps. 

- “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site. 

Additionally when you do any of the following; make a purchase or attempt to make a purchase through the Site, create an account on our site, subscribe to our services or publications, request marketing be sent to you, enter a competition, promotion or survey or give us feedback or contact us, we collect certain information from you, which can include your name, billing address, shipping address, payment information (including credit card numbers ), email address, and phone number. We refer to this information as “Order Information.”  

When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Order Information. 

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 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.  

2. 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: 

• Where we need to perform the contract we are about to enter into or have entered into with you, for example we use the Order Information that we collect generally to fulfil any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations) 
• Communicate with you
• Screen our orders for potential risk or fraud 
• When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services. 
• We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimise our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns). 
• 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. 

 

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. You have the right to withdraw consent to marketing at any time by contacting us. 

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, 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. 

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	(a) Identity   (b) Contact	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	(a) Identity   (b) Contact   (c) Financial   (d) Transaction   (e) Marketing and Communications	(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	(a) Identity   (b) Contact   (c) Profile   (d) Marketing and Communications	(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	(a) Identity   (b) Contact   (c) Profile   (d) Usage   (e) Marketing and Communications	(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)	(a) Identity  (b) Contact  (c) Technical	(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	(a) Identity   (b) Contact   (c) Profile   (d) Usage   (e) Marketing and Communications   (f) Technical	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	(a) Technical   (b) Usage	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	(a) Identity   (b) Contact   (c) Technical   (d) Usage   (e) Profile   (f) Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)

 

Marketing  

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

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 opted into receiving that marketing. 

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 hello@palomasproducts.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. 

3. Disclosures of your personal data 

We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Shopify to power our online store--you can read more about how Shopify uses your Personal Information here.  We also use Google Analytics to help us understand how our customers use the Site--you can read more about how Google uses your Personal Information here.  You can also opt-out of Google Analytics here. We also use Flodesk for our email marketing service, any emails sent by us are compliant with GDPR and allow you to easily unsubscribe at any time. Flodesk’s privacy policy can be found here. An unsubscribe and manage preferences  link is visible on all emails.  

Finally, we may also share your Personal Information to comply with applicable laws and regulations, for example to respond lawful request for information we receive, or to otherwise protect our rights. 

Behavioural Advertising

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work. 

You can opt out of targeted advertising by: 

FACEBOOK  

GOOGLE  

BING  

INSTAGRAM 

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal  

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. 

4. Do not Track 

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser. 

 5. International transfers 

We share your personal data, as above with Shopify, Google analytics and Flodesk. This will involve transferring your data outside the UK. 

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented :  

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data. 
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. 

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.  

6. 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.  

 7. Data retention 

How long will you use my personal data for? 

When you place an order through the Site, we will maintain your Order Information for our records unless and until you ask us to delete this information. If you sign up for a subscription or to receive our email marketing, we will hold your personal data to allow us to perform these services unless we are asked by you to stop these services. 

 8. Your legal rights 

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

Your right of access - You have the right to ask us for copies of your personal information.  

Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.  

Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.  

Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.  

Your right to object to processing - You have the right to object to the processing of your personal information in certain circumstances. 

Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances. 

Additionally, if you are a European resident we note that we are processing your information in order to fulfil contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States. 

OVERVIEW OF GDPR 

To exercise any of these rights contact us hello@palomasproducts.co.uk 

No fee usually required 

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 fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could 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 could 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.  

9. Glossary 

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). 

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 

External Third Parties 

Service providers acting as processors  who provide  IT and system administration services. 

Professional advisers acting as processors or joint controllers  including lawyers, auditors and insurers who provide consultancy,  legal, insurance and accounting services. 

HM Revenue & Customs, regulators and other authorities based in the United Kingdom 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. 

 

Contact us

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at hello@palomasproducts.co.uk