Privacy and Cookies Policy


INTRODUCTION


Naked Sprout is committed to protecting your personal data and respecting your privacy. This privacy policy aims to give you information on how we collect and look after your personal data when you visit our website (www.nakedsprout.uk).


By accessing and continuing to use the Naked Sprout website, you accept the terms of this privacy policy.


If you have any questions about this privacy policy, including any requests to exercise your legal rights as set out below, please contact us at hello@nakedsprout.uk


You may use our website to:


purchase any of our products


when you register with us as a customer,


when you otherwise contact us and


when we deliver the products you have ordered from us.


This policy will also tell you about your privacy rights and how the law protects you. If you do not buy via our website this policy will still apply


References to "you" or "your" are to you as an individual using our website or otherwise contacting Naked Sprout (either on behalf of yourself, your business or another individual or organisation).



IMPORTANT INFORMATION


This policy should be read together with our Terms & Conditions of sale and any additional privacy policy or fair processing notice we may provide on specific occasions (such as marketing events) 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 the other notices and does not override them.


Naked Sprout may update and amend this privacy policy from time to time. This version was last updated on 31st July 2021


It is important that the personal data we hold about you is accurate and up to date. We ask you to please keep us informed if your personal data changes that are relevant to us.


Our 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.


COMPANY DETAILS


Naked Sprout Ltd is a company incorporated in England and Wales with company number 12861535


Our registered office is M3 Merlin, Navigator Business park, Osprey Quay, Portland DT5 1FU and is referred to as "Naked Sprout", "we", "us" or "our" in this privacy policy.


Naked Sprout provides unbleached bamboo tissue products such as toilet paper and kitchen roll. Our website gives you the ability to purchase our products online and to sign up to these as a subscription service. As such, we need certain personal information to be able to provide you with our products and to operate your account and subscription.


Naked Sprout is a data controller and we are responsible for your personal data. We are bound by applicable data protection laws in respect of the handling and collection of your personal data and are registered as a data controller in England and Wales, with the Information Commissioner's Office (ICO) under the ICO number ZB022470.


WHAT TYPE OF DATA DO WE USE AND COLLECT?


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) or data relating to a corporate entity.


If you visit our website, contact us or make contact with us via our website or by telephone or email, we may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:


Identity Data may include first name, last name, username or similar

Contact Data may include delivery address, delivery instructions, email address and telephone/mobile number.

Financial Data may include payment card holder details (CHD), card type, expiry date and the last 4 digits of your card number.

Transaction Data may include details about your order history, payment instructions and payment history.

Technical Data may include 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, use of cookies or other devices to store and sometimes track information about you (more details on our use of cookies is set out in the section on Cookies below) and other technology on the devices you use to access this website or our software.

Profile Data may include your user id and password, purchases and orders made by you, your browsing history on our website, any event history, your account details, and feedback and survey responses.

Usage Data may include information about how you use our website, products and services.

Marketing and Communications Data may include your preferences in receiving marketing from us (and our third parties who provide marketing services) and your communication preferences.

Aggregated Data. We might aggregate your Usage Data to calculate the percentage of users accessing a specific website feature or Transaction Data for financial reporting and analysis. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.


Special Categories of Personal Data. We do not collect any special categories of personal data about you. This includes details about your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health, sex life or sexual orientation.


We do not actively collect any information about criminal convictions and offences.


Our website is not intended for children and in this respect we do not knowingly collect data relating to children.


IF YOU FAIL TO PROVIDE PERSONAL DATA


Where we need to collect personal data by law, or under the terms and conditions of sale 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 our products or to open up a customer account). In this case, we may have to suspend or cancel an order you have with us but we will notify you if this is the case at the time.


HOW DO WE COLLECT YOUR PERSONAL DATA?


Direct interactions. This is data you give us directly by filling in forms, website details etc.


Automated technologies or interactions. As you interact with our website we may automatically collect Technical or Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see the Cookies section below section.


Third parties or publicly available sources. We may receive personal data about you from various other third parties and public sources as set out below:


Technical and Usage Data from: (i) analytics providers, such as Google, based outside the EU; (ii) advertising networks; and (iii) social medial such as Facebook, Instagram and Twitter.


Identity and Contact Data from social media such as Facebook, Instagram and Twitter (for example when you like one of our posts or comment).


Identity, Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside the EU or within the US (and certified under the EU-U.S. Privacy Shield);


HOW DO 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:


In order to fulfil your orders – including sharing address data with our chosen shippers 


Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best product/service 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 make sure that 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 to by law). You can contact us for further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities

Consent means where we have obtained your agreement to process your personal data. Consent must be freely given, specific, informed and be an unambiguous indication of your wishes for us to process your personal data (this may be collected by you ticking a box). Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending marketing material to you via email, post, phone, sms, and social media. You have the right to withdraw consent to marketing at any time by contacting us at hello@nakedsprout.uk

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

MARKETING


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



We may send marketing material about Naked Sprout to you as a customer. We will only send marketing to you if you have previously bought similar products from us or have expressed an interest in our products – for example by setting up an account or entering your email address on our website contact form, and this is in our legitimate interests.


We will always give you the option to opt out of receiving this marketing when you first purchase or express an interest in our products and in every marketing communication afterwards. Profile and Marketing and Communications Data.

You may receive marketing communications from us after you have requested information from us or opened a customer account and, in each case, you have opted-in to receiving that marketing. You can withdraw your consent at any time


How to Opt out/unsubscribe



You can ask us to stop sending you marketing messages at any time by emailing us at hello@nakedsprout.uk.


Where you opt out of receiving these marketing messages, you may still receive messages for other purposes (such as providing the products and services to you).


Cookies.


Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a better experience when you browse our website and also allows us to improve our website. By continuing to browse the website, users 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 their computer. We only use (and store) non-essential cookies on your computer's browser or hard drive if you provide your consent.


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 can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you disable or refuse cookies when browsing our website, please note that some parts of our website may become inaccessible or not function properly.


Managing cookies: To enable and manage cookies, you can use your browser to do this. Each browser is different, so check the "Help" menu of your particular browser (or your mobile phone's handset manual) to learn how to change your cookie preferences.


Google Chrome

Internet Explorer

Mozilla Firefox

Safari

Opera

Google Analytics Opt Out 

The ICO (Information Commissioners Office) also provide helpful advice and guidance if oyu are unsure how to disabele cookies. This information can be found here: https://ico.org.uk/your-data-matters/be-data-aware/social-media-privacy-settings/


Duration of cookies:


Session (or Transient) Cookies


Session cookies are stored in your computer's memory for the length of your browsing session. They become inaccessible after the session has been inactive for a time and are automatically deleted from your computer when the browser is closed. They allow you to move from page to page without having to log-in repeatedly.



Persistent (or Permanent) Cookies


Persistent cookies are stored in your computer memory and are not deleted when the browser is closed. They are used to keep your preferences for the website, so they will be remembered for next time you visit the website. They are also used to collect information about the numbers of visitors, the average time spent on a particular page and analyse shopping behaviour on the website. This information is used to find out how well the website works and where it can be improved.



Flash Cookies (or Locally Shared Objects)


You probably have Adobe Flash installed on your computer. Websites that contain Flash can also store small files on your computer that are used in the same way as cookies.

Flash cookies can also back up the data that is stored in other cookies. When you delete cookies, your Flash cookies are not affected. So a website may still recognise you if it backed up the deleted cookie information on a Flash cookie.


 


We use the following types of cookie:



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 an online payment. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work.

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. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.

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 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.

DISCLOSURES OF YOUR PERSONAL DATA


For the purposes set out in the how will we use your personal data section we may have to share your personal data with the following parties:


External Third Parties such as:­


Service providers and developers based in (and outside) the UK who provide IT and system administration (including email, payment software and hosting) services.

Specialist suppliers for the packing, dispatch and delivery of our products (based in the UK).

Professional advisers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, legal, banking, accounting insurance and services.

HM Revenue & Customs, regulators, law enforcement bodies, police and other authorities based in the UK who require reporting of processing activities in certain circumstances (such as criminal activity, suspected or actual fraud or tax evasion).

Marketing and PR agencies based in the UK to help us with data analysis, social media marketing and other marketing (including if you agree to a publication / article with us).

Specific Third Parties such as Amazon Web Services (AWS) a cloud hosting provider, with their server based in Europe, who provide application servers and cloud storage.

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.


INTERNATIONAL TRANSFERS


We do not process your personal data in any country outside the European Union (EU).

However, certain third parties are based outside of the EU, so their processing of your personal data will involve a transfer of data outside the EU.

Whenever we transfer your personal data out of the EU, 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 by the European Commission.

Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

Where we use providers based in the US, we may transfer data to them if they are part of the EU-U.S. Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

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


DATA SECURITY


We have put in place appropriate security measures (including SSL technology) 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.

DATA RETENTION


How long will you use my personal data for?


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.

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.

We will generally retain our clients' data for a period of 7 (seven) years after a contract has ended, to ensure that we are able to assist you should you have any questions or feedback in relation to our products or services or to protect, or defend our legal rights, or for tax purposes.

Where we have processed your personal data to provide you with marketing communications with consent, we may contact you at least every 12 (twelve) months to ensure you are happy to continue receiving such communications. If you tell us that you no longer wish to receive such communications, your personal data will be removed from our marketing lists (and will be added to a "do not contact" list).

You may ask us to delete your data by emailing us at hello@nakedsprout.uk

In some circumstances we may 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.

YOUR LEGAL RIGHTS


You have a number of legal rights in relation to the personal information that we hold about you and you can exercise your rights by contacting us. These rights include:

Obtaining information regarding the processing of your personal information and access to the personal information which we hold about you.

Please note that there may be circumstances in which we are entitled to refuse requests for access to copies of personal information..

Requesting that we correct your personal information if it is inaccurate or incomplete.

Requesting that we erase your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal information but we are legally entitled to retain it.

Objecting to, and requesting that we restrict, our processing of your personal information in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal information but we are legally entitled to refuse that request.

In some circumstances, receiving some personal information in a structured, commonly used and machine-readable format and/or requesting that we transmit such information to a third party where this is technically feasible. Please note that this right only applies to personal information which you have provided to us.

Withdrawing your consent, although in certain circumstances it may be lawful for us to continue processing without your consent if we have another legitimate reason (other than consent) for doing so.

Lodging a complaint with the relevant data protection authority, if you think that any of your rights have been infringed by us.

We can, on request, tell you which data protection authority is relevant to the processing of your personal information.

 


If you wish to exercise any of the rights set out above, please contact us directly

No fee is usually 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 may refuse to comply with your request in these circumstances.

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.

We try to respond to all legitimate requests within one month. Occasionally it may 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.

COMPLAINTS ABOUT DATA PRIVACY


You have the right to make a complaint at any time to the ICO, the UK supervisory authority 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.