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Privacy Policy

LACEBY LTD TRADING AS ABSOLUTE COLLAGEN

PRIVACY POLICY AND COOKIE POLICY 1ST JULY 2021

Background

Laceby Ltd understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of all Our customers and everyone who visits Our Site and will only collect and use information in a manner consistent with your rights and Our obligations under the law.

This Policy applies to Our use of any and all data collected by Us in relation to your use of Our Site or any other dealings you have with Us. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

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;

"GDPR" means Regulation (EU) 2016/679 (General Data Protection Regulation);

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

“Our Site” means this website, displayed at eu.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; 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 ("DPO") is Jaz Singh. You can contact him at dataofficer@absolutecollagen.com.
  3. Our EU Data Representative is Instant EU GDPR Representative Ltd. You can contact them at contact@gdprlocal.com or on +353 (0) 1554 9700.
  4. We are registered in the United Kingdom under the Information Commissioner’s Office under registration number ZA250388.

3. Scope – what does this policy cover?

This Privacy Policy applies only to your dealings with Us as a customer or potential customer, or to your use of Our Site. It does not extend to any websites that are linked to or from Our Site (whether We provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

4. What data do we collect?

Some data will be collected automatically by Our Site (for further details, please see section 12 on Our use of Cookies), other data will only be collected if you voluntarily submit it, for example, when signing up for an Account or Our Mailing List. Depending upon Our interactions with you and your use of Our Site, We may collect some or all of the following data:

  • name;
  • contact information such as 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, 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 GDPR 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 if you sign up to Our Mailing List e.g. newsletters, alerts, birthday wishes etc. that you have subscribed to (you may unsubscribe or opt-out at any time by using the “unsubscribe” link within the footer of Our emails or by contacting Our customer service department via the online website form within the ‘Contact us’ page (https://eu.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 or telephone or 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:
Purpose/Activity Lawful basis for processing including basis of legitimate interest
To register you as a new customer or to sign you up for an Account. Performance of a contract with you.
To process and deliver any order you place with Us including:
  • Managing payments, fees and charges; and
  • Collecting and recovering money owed to Us.
  • Performance of a contract with you; and
  • Necessary for Our legitimate interests (to recover debts due to Us).
To manage Our relationship with you which will include:
  • Notifying you about changes to Our terms or privacy policy; and
  • Asking you to leave a review or take a survey.
  • Performance of a contract with you;
  • Necessary to comply with a legal obligation; and
  • 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.
  • Performance of a contract with you; and
  • 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 Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
  • 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); and
  • Necessary to comply with a legal obligation.
To operate market research and product development trials in order to provide products that best suit our customers
  • Consent; and
  • Necessary for Our legitimate interests (to study how customers use Our products, to develop them and grow Our business).
To deliver relevant Site content and advertisements to you and measure or understand the effectiveness of the advertising We serve to you. 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 Site, products/services, marketing, customer relationships and experiences. 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. Necessary for Our legitimate interests (to develop Our products/services and grow Our business).

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 EEA, 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 EEA which give personal data the same protection it has in the EEA.

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

  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.;
    • 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?

  1. 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 emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and/or by managing your Account).
  2. You may also wish to sign up to one or more of the telephone, corporate telephone and mailing preference services operating in Europe (for example, Bloctel in France and the National Directory Database in Ireland). 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 Our DPO at dataofficer@absolutecollagen.com or Our EU Data Representative at contact@gdprlocal.com or on +353 (0) 1554 9700 for more details.

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:-

    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.

  3. All Cookies used by and on Our Site are used in accordance with current data protection law.
  4. 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.
  5. 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.
  6. 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.
  7. 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.
  8. Our Site uses analytics services provided by Google Universal Analytics; Google Advance E-Commerce Tracking; Hotjar and Facebook Insights. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Site. This, in turn, enables Us to improve Our Site and the products and services offered through it. You do not have to allow Us to use these Cookies, as detailed below, however it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
  9. The analytics service(s) used by Our Site, uses Cookies to gather the required information. Some of these Cookies may be placed immediately when you first visit Our Site and it may not be possible for Us to obtain your prior consent.
  10. You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
  11. You can choose to delete Cookies at any time however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
  12. It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device, if you are unsure about adjusting your privacy settings.

13. Summary of your rights under GDPR

Under the GDPR, 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 the supervisory authority within your country (https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm) and/or complain to our EU Data Representative as noted in clause 2 (c) above;
    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 Our DPO at dataprotection@absolutecollagen.com or our EU Data Representative at contact@gdprlocal.com or on +353 (0) 1554 9700. 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 make a complaint at any time your country's own Supervisory Authority (https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm). We would, however, appreciate the chance to deal with your concerns before you approach your Supervisory Authority 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.