Politique de confidentialité

LACEBY LTD TRADING AS ABSOLUTE COLLAGEN

PRIVACY POLICY AND COOKIE POLICY 30TH JANUARY 2024

Background

1. Definitions and interpretation

In this Policy the following terms shall have the following meanings:

“Account” means an account required to access and/or use certain areas of the features of Our Site;

“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site.

Details of the Cookies used by Our Site are set out in section 12, below;

“Mailing List” means Our email and text message marketing list to which We distribute Our latest news and discount details;

“Our Site” means this website, displayed at www.absolutecollagen.com and any other URL connected to and operated by Us;

“Personal Data” means any information relating to an identified or identifiable natural person (a data subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person;

“UK and EU Cookie Law” means the relevant parts of the Privacy and Electronics Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and

“We/Us/Our” means Laceby Ltd, a limited company registered in England and Wales under 09659752 whose registered address is: Absolute Collagen, 49 Greek Street, London, London, England, W1D 4EG.

2. Information about us

1. Our Site is owned and operated by Us.

2. Our data protection officer is Jaz Singh. You can contact him at jaz.singh@absolutecollagen.com.

3. We are registered under the Information Commissioner’s Office under registration number ZA250388.

3. Scope – what does this policy cover?

4. What data do we collect?

• name;

• contact information such as postal addresses, email addresses and telephone numbers;

• information you may make available to us in connection with any product trials you choose to be involved in, including images or videos;

• demographic information such as post code, date of birth, preferences and interests;

• financial information such as credit / debit card numbers;

• IP address (automatically collected);

• web browser type and version (automatically collected);

• operating system (automatically collected); and

• a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected).

5. How do we use your data?

1. All Personal Data is stored securely in accordance with the Data Protection Act 2018 (“DPA”) and other applicable data protection laws. For more details on security see section 6, below.

2. We use your data to provide the best possible products and services to you. This includes:

   • Providing and managing your Account;

   • Providing and managing your access to Our Site;

   • Personalising and tailoring your experience on Our Site;

   • Supplying Our products and services to you;

   • Personalising and tailoring Our products and services for you;

   • Responding to communications from you;

   • Supplying you with emails or text messages if you sign up to Our Mailing List (which may include newsletters, alerts, reminders and birthday wishes, sent by email and/or text message, depending on which services you have subscribed to). You may unsubscribe or opt-out at any time by using the “unsubscribe” link within the footer of Our emails and text messages, or by contacting Our customer service department via the online website form within the ‘Contact us’ page (https://www.absolutecollagen.com/pages/contact);

   • Market research; and

   • Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience.

3. In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the products and services We can provide you without your consent for Us to be able to use such data.

4. With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone, text message or post with information, news and offers on Our products. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the DPA and other applicable data protection laws.

5. Under applicable data protection laws We will ensure that your Personal Data is processed lawfully, fairly, and transparently, without adversely affecting your rights. The bases for which We process your Personal Data is as follows:

6. How and where do we store your data?

1. We only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it. In any event, We will conduct an annual review to ascertain whether We need to keep your data. Data retention is defined as the retention of data for a specific period of time and for back up purposes. We shall not keep any Personal Data longer than necessary, but acknowledge that this will be dependent on the different types of documents and data that We have responsibility for. As such, Our general data retention period shall be for a period of 6 years.
2. Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site. We use industry standard encryption technologies when collecting or transferring customer credit card information exchanged with Our Site server - all your card details are passed from your browser to Our secure payment gateway using secure sockets layer (SSL) encryption. Our payment gateway providers use secure sockets layer (SSL) encryption system. All other information transferred is conducted through a secure connection. Where We have given you (or where you have chosen) a password which enables you to access certain parts of the Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. All information provided through the Site is stored on servers located in either the United Kingdom, the European Economic Area (EEA), Canada and/or the United States of America. It will be processed by staff operating in the UK who work for Us. Such staff may be engaged in, among other things, the processing of your payment details and the provision of support services. By submitting your personal information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely in accordance with this Privacy Policy.
3. Whenever We transfer your personal data outside 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; or
   • 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.

4. Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.

7. Do we share your data?

1. We may share your data with other companies in Our group and would principally be shared for sales and product reporting purposes.
2. We may contract with third parties to supply products and services to Us, or to you on Our behalf. These products and services may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law. We currently contract with the following categories of third parties:
   • Payment Gateway providers, including Paypal Holdings, Inc, Stripe Inc, and Amazon.com, Inc;
   • Software houses for ERP, WMS, CRM and Carrier facilitation and associated third party support providers including Klaviyo, Inc;
   • Web Development Agencies;
   • Web Hosting and Ecommerce Services, including Shopify Inc. and Recharge Inc.;
   • Advertising partners, including digital advertising partners such as social media sites and Google;
   • Carrier & Freight Providers; and
   • Bank, Credit Card and Financial Institutions including Klarna Bank PB (publ) (“Klarna”).
   • Where your Personal Data is shared with any of the above categories of third parties, those third parties may be acting as data controllers in their own right in providing their services and We are not responsible for their handling of your Personal Data. Please find general information about any relevant party on its website. Your Personal Data will handled in accordance with the relevant party’s privacy policy.
3. We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.
4. In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.

8. What happens if our business changes hands?

1. We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Data provided by users will, where it is relevant to any part of Our business so transferred, be transferred along with that part and the new owner or newly controlling party will be permitted to use the data for the purposes for which it was originally collected by Us.
2. In the event that any of your data is to be transferred to a new business owner, you will be informed of the changes.

9. How can you control your data?

(a) When you submit information to Us, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data, including the ability to opt-out of receiving marketing communications from Us which you may do by:

a. unsubscribing using the links provided in Our emails and text messages

b. advising Our operator whilst on the telephone;

c. opting out of receiving marketing communications at the point of providing your details;

d. contacting Our customer service department via the online form within the ‘Contact us’ page (https://www.absolutecollagen.com/pages/contact); or

e. managing your Account online.

(b) You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

10. Your right to withhold information and your right to withdraw information after you have given it

1. To use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data. However, as detailed in section 4, some data, such as your IP address, may be collected automatically.
2. You may restrict your internet browser’s use of Cookies. For more information, see section 12.
3. Where Our lawful basis for processing your Personal Data is consent, you may withdraw your consent for Us to use your Personal Data as set out in section 5 at any time by contacting Us using the details set out in section 15. However, by doing this, you acknowledge this may limit Our ability to provide the best possible products and services to you.

11. How can you access your data?

You have the legal right to ask for a copy of any of your Personal Data held by Us (where such data is held). Please contact Us for more details, through Our data protection officer, at jaz.singh@absolutecollagen.com or using the contact details below in section 15.

12. What cookies do we use and what for?

1. Our Site may place and access certain “first party Cookies” on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products and services. For more details, please refer to section 5, above, and to section 12(f) below. We have carefully chosen these Cookies and have taken steps to ensure that your privacy is protected and respected at all times.
2. By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. We use third party Cookies on Our Site to:

   • place advertisements for Our products on other external sites. We do this by allowing third parties including Google, Adserve and Bing to place cookies on Our Site which allows them to identify your visit to Our Site and preferences shown whilst on it, and your visits to subsequent third party websites in their adserving network. This allows Us to serve tailored advertisements to you on those third party websites based on the information We have collected on your interests whilst you were visiting Our Site;

   • help the Site to function correctly and ensure that the ‘add to bag’, navigation and country site settings are maintained;

   • monitor the Site’s performance and ensure that We deliver a fast browsing experience;

   • allow you to share content with social networks, express interest in content and connect with your social media networks;

   • allow Us to collect anonymous data about Site usage to help Us improve the usability, content and user experience of the Site. This includes site analytics cookies such as Google Analytics and Hotjar. We also use third parties such as Google Analytics and Hotjar to collect information about your online activity on the Site, such as the web pages you visit, the links you click, and the searches you conduct on the Site. We use the information to compile reports and to help Us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the Site, where visitors have come to the site from and the pages they visited. The cookies also assess third party conversion by allowing Us to collect anonymous data about how Our marketing is performing.

For more information about the information gathered using Google Analytics please visit:-
https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage

https://support.google.com/analytics/answer/6004245#zippy=.

For more information about the information gathered using Hotjar please visit:- https://help.hotjar.com/hc/en-us/articles/115011789248-Hotjar-Cookies.

For more details, please refer to section 5, above, and to section 12(f) below. These Cookies are not integral to the functioning of Our Site.

(c) All Cookies used by and on Our Site are used in accordance with current data protection law.

(d) Before any Cookies are placed on your computer or device subject to section 12(b), you will be shown a pop-up/message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. You will be given the opportunity to allow only first party Cookies and block third party Cookies.

(e) Certain features of Our Site depend on Cookies to function. Data protection law deems these Cookies to be “strictly necessary” (“Necessary Cookies”). Necessary Cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.

(f) Your consent will not be sought to place Necessary Cookies. You may still block Necessary Cookies by changing your internet browser’s settings as detailed below in section 12.j, but please be aware that Our Site may not work as intended if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

(g) Other cookies include functionality cookies, analytics cookies and marketing cookies, as follows:-

• Functionality cookies enable a website to provide enhanced functionality and personalisation, for example to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in. They may be set by Us or by third party providers whose services We have added to Our pages;
• Analytics cookies help website owners to monitor site traffic and analytics, for example to understand how visitors interact with websites by collecting and reporting information anonymously. This also enables Us to run tests and optimise Our Site’s experience; and
• Marketing cookies allow Us to tailor and measure the effectiveness of Our advertising and are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers.

13. Summary of your rights under the UK GDPR and the Data Protection Act 2018 (DPA)

Under the UK GDPR and the DPA, you have:

1. the right to request access to, deletion of or correction of, your Personal Data held by Us;
2. the right to complain to a supervisory authority (which in the UK is the Information Commissioner’s Office: www.ico.org.uk);
3. be informed of what data processing is taking place;
4. the right to restrict processing;
5. the right to data portability;
6. object to processing of your Personal Data;
7. rights with respect to automated decision-making and profiling (see section 14 below).

To enforce any of the foregoing rights or if you have any other questions about Our Site or this Privacy Policy, please contact Us using the details set out in section 15 below.

14. Automated decision-making and profiling

1. It is not Our policy to carry out automated decision-making and profiling; however in the event that We were to use Personal Data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on You, You have the right to challenge such decisions under data protection law, requesting human intervention, expressing your own point of view, and obtaining an explanation of the decision from Us.
2. The right described in section 14(a) does not apply in the following circumstances:
   • The decision is necessary for the entry into, or performance of, a contract between the You and Us;
   • The decision is authorised by law; or
   • You have given your explicit consent.
3. Where We use your Personal Data for profiling purposes, the following shall apply:
   • Clear information explaining the profiling will be provided, including its significance and the likely consequences;
   • Appropriate mathematical or statistical procedures will be used;
   • Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
   • All Personal Data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.

15. Contacting us

1. If you have any questions about Our Site or this Privacy Policy, please contact Us through Our online website form (https://www.absolutecollagen.com/pages/contact), by telephone on +44 (0) 20 3962 0370, during the hours of 9am and 5pm, Monday to Friday or by post at Laceby Ltd, Absolute Collagen, 49 Greek Street, London, London, England, W1D 4EG. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 11, above).
2. 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.

16. Changes to our privacy policy

We may change this Privacy Policy as We may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.