Date: 08/06/2020

 

Privacy Statement from Holpura.

We take your privacy seriously and will only use your personal information to administer your account and to provide the products and services you have requested from us.  We will never sell, share or use your personal information other than as described here.

 

WHAT IS PERSONAL DATA?

“Personal data” means any information or pieces of information that could identify you either directly (e.g. your name) or indirectly (e.g. through pseudonymised data, such as a unique ID number). This means that personal data includes things like email/home addresses, usernames, profile pictures, personal preferences and shopping habits, user generated content, financial information, and health information. It could also include unique numerical identifiers like your computer’s IP address or your mobile device’s MAC address, as well as cookies.

 

This Privacy Policy covers all personal data about you that is collected and used by Holpura.

 

ABOUT THIS PRIVACY POLICY

This policy sets out how we will use and share the information that you give us.  This policy describes your relationship with Holpura. 

 

WHO ARE WE AND HOW TO CONTACT US.

Holpura provides plant based haircare and skincare solutions that promote healthy hair and skin.  

 

The data controller is: Tasharna Gardner and you can get in touch with us in any of the following ways:

 

Email: [email protected]

Website: www.holpura.com

 

HOW TO CHANGE YOUR PREFERENCES

You can visit the Holpura website to contact us to change your preferences at any time. 

 

HOW WE OPERATE.

We operate in line with EU GDPR [May 2018] data protection guidelines.  We are committed to maintaining your personal rights and allow all users to change or withdraw their opt-in options at any time.  We will also advise you on how to complain to the relevant authorities, namely the Information Commissioner’s Office.

WHO THIS PRIVACY POLICY APPLIES TO

This policy relates to customers of Holpura, our number one priority.  We want to learn as much about you and your requirements as possible to deliver the best products and all-round service. We want to be as transparent with you on what information we collect and what we use it for; there are many ways that you may share your personal data with us, and ways we may collect it. 

 

HOW WE COLLECT OR RECEIVE YOUR PERSONAL DATA

 

This section describes the lawful basis for processing your data and applies to the information about yourself that you choose to provide us with or that you allow us to collect. This includes:

• Your consent – This applies where you provide your personal data and specifically consent to us using it to provide you with a specific service, such as:                                
• Marketing communications: If you later ask us to stop sending you marketing communications, we need to keep some of your personal data on a suppression list so that we can make sure we do not contact you again. This is a legal obligation; and
• Storing certain cookies on your device: We may place targeted advertising cookies (allowing us to tailor services we offer, specifically to you), analytical cookies (also known as performance cookies and measure/record your interaction with our site so we can make improvements) on your device. Further information can be found in the ‘Cookies’ section in this document.

• The performance of a contract – This applies where you provide us with your personal data in order for us to provide you with a service (e.g. you wish to purchase a product and we can manage the associated logistics). 

• To comply with legal obligations – This is where you provide us with your personal data which we need to keep for our legal reasons (e.g. when you make a purchase we need to keep your transaction information to comply with our tax and financial reporting obligations). 

 

IN WHICH CONTEXT IS YOUR PERSONAL DATA COLLECTED? 

Newsletter and marketing subscription – Where your personal data are collected when you subscribe to receive our marketing communications.

• What personal data may we hold about you? 

• First name and surname
• Email address
• Gender
• Address
• Phone number
• Preferences
• Order details

• How and why may we use it?

• Send you marketing communications (where you have asked us to) which may be tailored to you based on the personal data we know or learn about you and your preferences.
• Show you marketing communications on other websites, including social media platforms. Note that you may also see our ads on other websites, including on social media sites, but these may not be tailored to you
• Keep an up to date suppression list if you have asked not to be contacted
• Run analytics or collect statistics and/or
• Send content on your behalf to your friends and/or family. 

PURCHASES AND ORDER MANAGEMENT 

Where your personal data is collected during the purchase process made on the Holpura website, or in person. 

• What personal data may we hold about you?

• First name and surname
• Email address
• Address
• Phone number
• Preferences
• Transaction information including purchased products
• Payment and information and/or
• Purchase history 

• How and why may we use it? 

• Contact you to finalise your order where you have saved your shopping cart or placed products in your cart without completing the checkout process
• Inform you when a product you wanted to purchase is available
• Process your order including delivering the product to the address you indicated
• Manage payment. Please note that your payment information (credit card number/bank account details) are not collected by us directly but by secure payment service providers
• Manage any contact you have with us about your order
• Secure your transactions against fraud. We may use a third-party provider’s solution to detect fraud and make sure that payment is completed
• If you place a purchase using a registered account, we will add this transaction to your profile so we can understand your interests and preferences and you will see a record of your transactions with us within your account (where applicable)
• Manage any dispute relating to a purchase; and/or
• Run analytics or collect statistics. 

REASONS FOR COLLECTING THIS DATA:

• To manage your orders
• Send you marketing communications (where you have opted in) which may be tailored to your “profile” (i.e. based on the personal data we know about you and your preferences)
• Offer you a loyalty program
• Offer personalised services based on your characteristics
• Allow you to manage your preferences
• Monitor and improve our websites and apps
• Run analytics or collect statistics
• Secure our websites and protect you and us against fraud
• Respond to your questions and otherwise interact with you; and/or
• Manage any competitions, promotions, surveys or contests you enter.

COOKIES

Where your personal data is collected by cookies or similar technologies (“cookies”*) when you browse the Holpura website where we have cookies.

 

*cookies are small text files stored on your device (computer, tablet or mobile) when you are on the Internet, including on this website. 

 

WHAT PERSONAL DATA MAY WE HOLD ABOUT YOU? 

Data related to your use of our websites, including:

• Where you came from (e.g. social media channel or a search engine)
• Login details
• Location
• Data related to your navigation on our apps/websites, incl. scroll/mouse movement (but in a manner that does not identify you);
• Videos you watched
• Pages/ads/content you looked at, clicked or tapped on
• Duration of your visit and/or
• Products you searched for and/or selected to create your basket. 
• Technical information:

• Your IP address

HOW AND WHY MAY WE USE IT? 

We use cookies, together with other personal data you have already shared with us (such as previous purchases, or whether you’re signed up to our email newsletters) for the following purposes: 

 

• To deliver targeted advertising, that is to show you:
• online advertisements for products which may be of interest to you, based on your previous behaviour; and/or
• ads and content on social media platforms or other websites. 
• You can opt out of targeted advertising by using the function available on our website (where applicable), or in your browser settings. For opting out of targeted advertising on social media platforms, please visit the relevant social media platform to explore the options they may provide. 

• To tailor our services for you, that is to:
• show you recommendations, marketing, or content based on your profile and interests; and/or
• display our websites in a tailored way, for example, show you products we think you might like. 
• To allow our websites/apps to function properly, that is to:
• ensure the proper display of content;
• create and remember your shopping cart;
• create and remember your account login details;
• interface personalisation, such as language, or any user-interface customisation (i.e. parameters attached to your device including your screen resolution or font preference), etc.
• perform troubleshooting; and/or
• improve user experience and our websites/apps, for example, by testing new ideas or layouts.
• Please note that we only track your navigation on the website/app (e.g., mouse movements) to ensure our websites/apps function properly, for troubleshooting, and to improve user experience, as explained above. We do so in a way that does not identify you and use encryption mechanisms to ensure that the personal data provided on the website/app is always masked and never recorded.

SCOPE OF CONSENT

By submitting your personal data on this site, you are affirming your explicit consent for such information to be used in accordance with this privacy policy.  You will be able to withdraw that consent at any time by the methods described.

 

OPTING OUT AT A LATER DATE

Once you have given your consent, you can amend or withdraw your consent at anytime and update your preferences via the Holpura website.  You can also choose to object to processing at anytime.  We respect all user rights as defined in GDPR.  If you have any comments or wish to complain please visit Holpura.com or contact us anytime.

HOW WE STORE AND PROCESS YOUR DATA.

Your account data will be collected and stored and processed in the UK and USA only.  Your data will be stored for six years or as long as required or until i) you ask in writing for your data to be deleted, ii) there has been a long period of inactivity; this period is determined in accordance to local regulations.  In order to provide updates and offers that may be of interest to you, we use recognised third parties to take payment, manage our company accounts and provide banking services.  We will store transactions, payment and order data for up to 7 years or for as long as required by UK financial and company regulations.  These third parties may operate outside the EU.

OUR OBLIGATIONS.

We are a data controller.  In relation to the information that you provide to us, we are legally responsible for how that information is handled.

 

We will comply with the Data Protection Act 1998 and the GDPR [2018] in the way we use and share your personal data.  Among other things, this means that we will only use your personal data:

 

• Fairly and lawfully
• As set out in the legislation and this policy
• To the extent necessary for these purposes

We will process your personal data ourselves as the data processor.  We will take reasonable precautions to safeguard the personal information that you supply.

 

Holpura may from time to time use your information for marketing, account management or relationship management purposes.  The main purpose of this is to provide you with information about goods and services which we think may be of interest to you and/or to maintain any existing relationship we may have with you. 

 

THIRD PARTIES

Your data is not shared with any third parties other than as described here.

SECURITY

We will report any breaches or potential breaches to the appropriate authorities within 24 hours and to anyone affected by a breach within 72 hours.  If you have any queries or concerns about your data usage please contact us.

LEGITIMATE INTERESTS

Under the Data Protection Act, we are also permitted to share some information with third parties who use such data for non-marketing purposes (including credit and risk assessment and management, identification and fraud prevention, debt collection and returning assets to you).

CONTACTING US, EXERCISING YOUR INFORMATION RIGHTS AND COMPLAINTS

If you have any questions or comments about this Privacy Policy, wish to exercise your information rights in connection with the personal data you have shared with us or wish to complain, please contact: The Data Protection Officer at Holpura. We will process SARs within 20 days, SAR responses are usually free but we reserve the right to charge for excessive or unfounded requests. We fully comply with Data Protection legislation and will assist in any investigation or request made by the appropriate authorities.