When we process your personal data we are required to comply with the General Data Protection Regulation 2016 (including any UK version of GDPR that is implemented as a result of Brexit) (“GDPR”) and the Data Protection Act 2018, which supplements GDPR in the UK (the “DPA"). The DPA and GDPR are together referred to in this notice as the “Data Protection Laws”.
Your personal data includes all the information we hold that identifies you or is about you, including but not limited to your name, email address, postal address, and in some cases opinions that we document about you. It does not include data where the identity has been removed and is therefore anonymous. More information about the types of personal data we process about you is set out below.
Everything we do with your personal data counts as processing it, including collecting, storing, amending, transferring and deleting it. We comply with the Data Protection Laws to make sure that your information is properly protected and used appropriately.
1. Our responsibilities
1.1 We are Ferndale Pharmaceuticals Limited (a company registered in England with registered company number 04720051 and having its registered office at Unit 740, Street 2, Thorp Arch Estate, Wetherby, England LS23 7FX) is the controller of the personal data you provide. We also trade as AesthetiCare, our commercial division that specialises in skincare, skin-health, beauty and wellbeing products.
2. What data do we process about you?
2.1 If you purchase products from us for your own use:
2.1.1 We will collect the following information about you as a result of you placing an order with us:
220.127.116.11 Your first name and last name;
18.104.22.168 Your title;
22.214.171.124 Email address;
126.96.36.199 Telephone number;
188.8.131.52 Delivery / residential address;
184.108.40.206 Transaction data including details of products you have purchased from us; and
220.127.116.11 Technical Data (described in more detail below) as a result of you using our website.
2.1.2 We refer to the information set out above as “Customer Information” throughout this policy.
2.2 If you are one of our suppliers or a business customer
2.2.1 We will collect individual contact information about you if you work for one of our suppliers. This is usually limited to your name, business email address and the name of the company for which you work.
2.2.2 We will collect individual contact information about you if you work for a business that is purchasing products from us. This is usually limited to your name, business email address and the name of the company for which you work.
2.2.3 We refer to this information as “Business Information” throughout this policy.
2.3 If you use our website or communicate with us but you do not place an order
2.3.1 We will collect the following information as a result of you accessing our website or using some of the functionality on our website or as a result of you contacting us by any other means:
2.5 Special categories of data
We do not collect any special categories of data about you
3. We may receive your personal data from a third party
3.1 If you submit a query to one of our manufacturers, the manufacturer will pass your details to us so we can respond to you. This information will usually be limited to your name, email address and the products you have purchased or want to purchase from us together with any other personal data you provide in your communications. We use this information in the same way that we use Contact Information, referred to throughout this policy.
4. Why do we process your personal data?
4.1.1 We process Customer Information on the basis of our contract with you to:
18.104.22.168 provide the products you have purchased from us; and
22.214.171.124 provide you with assistance and support in relation to the products you have purchased where necessary.
4.1.2 Any marketing communications we send to you are sent on the grounds of your consent. You may withdraw your consent at any time. This will not affect the lawfulness of any processing we carried out prior to you withdrawing your consent.
We process Business Information on the grounds of our legitimate interests in maintaining a relationship with the company for which you work in order to purchase products from them.
4.3 Website Users
4.4 Who will receive your personal data?
4.4.1 Your personal data is only transferred to the extent that this is necessary. Recipients of your personal data include:
126.96.36.199 third party delivery companies delivering products to you if you are one of our customers;
188.8.131.52 manufacturers of the product you have purchased in case we need them to investigate the issue or complaint you have raised in respect of the product;
184.108.40.206 legal advisers to the extent they need to see your personal data to provide us with legal advice;
4.4.2 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.
4.4.3 We may transfer your personal data outside of the EEA if we need to in line with section 220.127.116.11 above and the manufacturer is located outside of the EEA. We transfer your personal data either in accordance with an adequacy decision issued by the European Commission or, where no adequacy decision has been made, in accordance with Standard Contractual Clauses (adopted by the European Commission) which we have entered into with the manufacturer.
5. How long will we keep your personal data?
5.1 Customers and Suppliers
Your personal data is retained for no more than 7 years from the data you place an order with us. This is a rolling period that will recommence each time you place an order with us. It is retained for this period in case any issues arise or in case you have any queries. Your information will be kept securely at all times. Following the end of the 7 year period, your files and personal data we hold about you will be permanently deleted or destroyed. If we are required to obtain your consent to send you marketing communications, any information we use for this purpose will be kept until you withdraw your consent, unless we have other legitimate reasons to retain the data.
5.2 Website users
We retain Contact and Technical Information for as long as we need it for the purposes set out above, and so this period will vary depending on your interactions with us. Where we no longer have a need to keep your information, we will delete it.
6. What are your rights?
You benefit from a number of rights in respect of the personal data we hold about you. We have summarised your rights below, and more information is available from the Information Commissioner’s Office website (https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/). These rights apply for the period in which we process your data.
6.1 Access to your data
6.1.2 We will provide the information free of charge unless your request is manifestly unfounded or excessive or repetitive, in which case we are entitled to charge a reasonable fee. We may also charge you if you request more than one copy of the same information.
6.1.3 We will provide the information you request as soon as possible and in any event within one month of receiving your request. If we need more information to comply with your request, we’ll let you know.
6.2 Rectification of your data
If you believe personal data we hold about you is inaccurate or incomplete, you can ask us to rectify that information. We will comply with your request within one month of receiving it, unless we don’t feel it’s appropriate in which case we’ll let you know why. We will also let you know if we need more time to comply with your request.
6.3 Right to be forgotten
6.3.1 In some circumstances, you have the right to ask us to delete personal data we hold about you. This right is available to you:
6.3.2 There are certain scenarios in which we are entitled to refuse to comply with a request. If any of those apply, we will let you know.
6.4 Right to restrict processing
6.4.1 In some circumstances you are entitled to ask us to suppress processing of your personal data. This means we will stop actively processing your personal data but we don’t have to delete it. This right is available to you:
6.5 Data portability
6.5.1 You have the right to ask us to provide your personal data in a structured, commonly used and machine-readable format so that you are able to transmit the personal data to another data controller. This right only applies to personal data you provide to us:
6.5.2 We’ll respond to your request as soon as possible and in any event within one month from the date we receive it. If we need more time, we’ll let you know.
6.6 Right to object
6.6.1 You are entitled to object to us processing your personal data:
6.6.2 We do not intend to use your personal data to send you direct marketing nor for scientific or historical research and statistics.
6.6.3 In order to object, you must have grounds for doing so based on your particular situation. We will stop processing your data unless we can demonstrate that there are compelling legitimate grounds which override your interests, rights and freedoms or the processing is for the establishment, exercise or defence of legal claims.
6.7 Automated decision making
Automated decision making means making a decision solely by automated means without any human involvement. We don’t carry out any automated decision making using your personal data.
6.8 Your right to complain about our processing
If you think we have processed your personal data unlawfully or that we have not complied with GDPR, you can report your concerns to the supervisory authority in your jurisdiction. The supervisory authority in the UK is the Information Commissioner’s Office (“ICO”). You can call the ICO on 0303 123 1113 or get in touch via other means, as set out on the ICO website - https://ico.org.uk/concerns/.
7. Any questions?
If you have any questions or would like more information about the ways in which we process your data, please contact firstname.lastname@example.org.