We at The Olfactiv respect your privacy and we are committed to protecting your personal data, as well as respecting the consented use of it. This Privacy Notice will help you understand what personal data we collect, why we collect it and what we do with it.
Version 1 – Updated 05 July 2018
Bountiful Creative LTD, the controlling company of the The Olfactiv brand, is the controller and is responsible for your personal data (collectively referred to as The Olfactiv, “we”, “us” or “our” in this privacy notice).
We have appointed a data protection officer (DPO) internally who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO by emailing us on firstname.lastname@example.org
You have the right to make a complaint at any time to the Information Commissioner’s Office (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 we encourage you to please contact us in the first instance. This Privacy Notice applies to personal data collected by The Olfactiv in connection with the services and products we offer.
This Privacy Notice also applies to The Olfactiv ’s marketing content, including offers and advertisements for The Olfactiv products and services, which we (or a service provider acting on our behalf) send to you on third-party websites, platforms and applications based on your site usage information. These third-party websites generally have their own Privacy Notice and Terms and Conditions. We encourage you to read them before using those websites.
the data we collect about you
Personal data means any information that can be used to identify directly or indirectly a specific individual. This definition includes personal data collected through our website, applications and branded pages on third-party platforms and applications accessed or used through third-party platforms.
You may be asked to provide your personal data when you are in contact with us. You are not required to provide The Olfactiv the personal data that we request, but if you choose not to do so, we may not be able to provide you with our products or services, or with a high quality of service or respond to any queries you may have.
Ways in which we collect your personal data
We may collect personal data from a variety of sources. This includes:
- Personal data that you give us directly. We collect personal data you provide us when you sign up for a marketing newsletter, request marketing materials to be sent to you, fill in our contact form, complete a survey, enter a competition or register for an account to buy our products. In so doing, we may ask for personal data, such as your name, gender, address, email address, telephone number or credit card details.
- Personal data we collect from other sources. We collect personal data from other sources including our trusted partnerships with third-parties and where we operate The Olfactiv accounts on third-party platforms: For example, when you use the “like” functionality on Facebook or the +1 functionality on Google+. Additionally, we receive information about you and other visitors’ interactions with our advertising to measure whether our advertising is relevant and successful. We also collect information about you and your activities from a third-party when we jointly offer services or products, or from third-party data enrichment providers who may deliver insights to The Olfactiv about the personal data we hold.
How do we protect children’s privacy?
The Olfactiv’s website is designed and intended for use by adults. If we discover that we have collected personal data from a child without consent from a parent or guardian, where such consent should have been obtained, we will delete that personal data as soon as practical.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We collect, process and disclose your personal data for the following purposes:
- To process your payments, if you purchase our products, to provide you with your order status, deal with your enquiries and requests, and assess and handle any complaints;
- To process and answer your inquiries or to contact you to answer your questions and/or requests;
- To develop and improve our products, services, communication methods and the functionality of our website;
- For the purposes of competitions or promotions that you have entered;
- To communicate information to you and to manage your registration and/or subscription to our newsletter or other communications;
- To manage our everyday business needs regarding your participation in our competitions or promotional activities or request;
- To authenticate the identity of individuals contacting us by telephone, electronic means or otherwise;
- To understand and assess the interests, wants, and changing needs of consumers, to improve our website, our current products and services, and/or developing new products and services; and
- To provide personalised products, communications and targeted advertising as well as product recommendations to you.
When we collect and use your personal data for purposes mentioned above or for other purposes, we will inform you before or at the time of collection.
Where appropriate, we will ask for your consent to process the personal data. Where you have given consent for processing activities, you have the right to withdraw your consent at any time.
The Olfactiv uses your personal data to build profiles. We create profiles by analysing the information about your online surfing, searching and buying behaviour and your interactions with our brand communications by building segments (creating groups that have certain common characteristics) and by placing your personal data in one or more segments. These segments are used by The Olfactiv to personalise the website and our communications to you (such as showing relevant content to you when you visit our site or in a newsletter to you), and to display relevant offers and advertisements from the The Olfactiv brand on the The Olfactiv site, and via third-party websites. The segments can also be used for third-party campaigns on the The Olfactiv site. The Olfactiv profiles your data where you have provided consent for us to do so; for example, accepting the setting of cookies on your browser online or signing up for email newsletters from one of our brands.
You can withdraw your consent to prevent your personal data being used this way at any time using the manage cookies section of our Cookie Notice or unsubscribing to the use of your email address if you have logged into one of our websites or signed up to any marketing newsletters.
By way of example –
- The Olfactiv collects data, with your consent, from:
- Our websites about what you view and the way you interact with our content;
- Our digital display advertising that we serve to you on social platforms and other publisher’s websites; and
- Forms you fillin online and send to us about what your interests are.
- We also track the products you buy when you click on one of our display adverts and go on to purchase something from a selection of our retail partners.
- If you have asked to receive emails or SMS communications from us, we track whether you open, read or click on the content to see what you are interested in so that we can give you more content that we think you are more likely to enjoy.
- We use this data to profile your likes and dislikes. For instance, if we see that you are regularly viewing our blog, and you have opted in to receiving emails from us, we might give you an update on the new blog posts that have just hit the site for your interest, or we may tailor our web content when you visit towards things we think you’ll be most interested in.
- Based on this profile information, we may also give you advertising that we think you will like and want to see as you view content from us or from our network of publishers that we advertise with. Sometimes, with your consent, we may use your current location to serve advertising to you that is to do with promotions or events that are happening nearby that we think you might be interested in.
- We may also use information you have provided to selected third-parties and consented to be shared, like your age, gender, life stage, lifestyle and wider interests to identify people who we think will have similar interests to you and who we believe will be interested in similar advertising.
Who will it be shared with?
The Olfactiv shares your personal data internally and with selected third-parties in the following circumstances:
- Third-party service providers. In order to carry out your requests, respond to your inquiries, fulfil your orders, honour coupons, provide you with samples, enable you to participate in sweepstakes or make various other features, services and materials available to you through our websites we share your personal data with third-party service providers that performfunctions on our behalf, such as companies that: host or operate The Olfactiv’s website, process payments, analyse data, provide customer service, postal or delivery services, and sponsors or other third-parties that participate in or administer our promotions. They have access to personal data needed to perform their functions but may not use it for other purposes. Further, they must process this personal data in accordance with this Privacy Notice and as permitted by applicable data protection laws and regulations.
- Other third-parties. Your personal data will also be used by us or shared with our sponsors, advertisers, advertising networks, advertising servers, social media networks, and analytics companies or other third-parties in connection with marketing, promotional, data enrichment and other offers, as well as product information.
- Business transfers. Your personal data will be used by us or shared with the joint data controllers for internal reasons, primarily for business and operational purposes. As we continue to develop our business, we may sell or purchase assets, subsidiaries or business units. In such transactions, your personal data generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Notice (unless, of course, you consent otherwise). If another entity acquires us, our businesses or substantially all or part of our assets, or assets related to The Olfactiv’s website, your personal data will be disclosed to such entity as part of the due diligence process and will be transferred to such entity as one of the transferred assets. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such personal data will be considered an asset of ours and as such it is possible they will be sold or transferred to third-parties.
- Legal disclosure.
We may transfer and disclose your personal data to third-parties:
- To comply with a legal obligation;
- When we believe in good faith that an applicable law requires it;
- At the request of governmental authorities conducting an investigation;
- To detect and protect against fraud, or any technical or security vulnerabilities;
- To respond to an emergency; or otherwise
- To protect the rights, property, safety, or security of third-parties, visitors to The Olfactiv’s website, The Olfactiv or the public.
International data transfers
We do not transfer your personal data outside the European Economic Area
How we protect your personal data
The Olfactiv takes the security of your personal data very seriously. We take every effort to protect your personal data from misuse, interference, loss, unauthorised access, modification or disclosure.
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.
How long we keep your personal data for
We will keep your personal data for as long as we need it for the purpose it is being processed for. For example, where you make a purchase online with us we will keep the data related to your purchase, so we can perform the specific contract you have entered and after that, we will keep the personal data for a period which enables us to handle or respond to any complaints, queries or concerns relating to the purchase.
Your data may also be retained so that we can continue to improve your experience with us and to ensure that you receive any loyalty rewards which are due to you.
We retain the identifiable data we collect directly for targeting purposes for as little time as possible, after which we will permanently delete it.
We will actively review the personal data we hold and delete it securely, or in some cases anonymise it, when there is no longer a legal, business or consumer need for it to be retained.
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us – email@example.com.
How do you contact The Olfactiv?
If you have any questions or concerns about The Olfactiv’s Privacy Notice or data processing or if you would like to make a complaint about a possible breach of local privacy laws, please do so by sending an email to firstname.lastname@example.org.
When a privacy question or access request is received we will seeks to address the specific concern or query which you are seeking to raise. Where your issue may be more substantive in nature, more information may be sought from you. All such substantive contacts receive a response. If you are unsatisfied with the reply received, you may refer your complaint to the relevant Supervisory Authority in your Country. If you ask us, we will endeavour to provide you with information about relevant complaint avenues which may be applicable to your circumstances.
CHANGES TO THE PRIVACY NOTICE
We will update this Privacy Notice when necessary to reflect customer feedback and changes in our products and services. When we post changes to this statement, we will revise the “last updated” date at the top of this Notice. If the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Privacy Notice changes). We will also keep prior versions of this Privacy Notice in an archive for your review.
We will not reduce your rights under this Privacy Notice without your consent.
Additional Privacy Terms or Notices
In addition to this Privacy Notice, there may be specific campaigns or promotions which will be governed by additional privacy terms or notices. We encourage you to read these additional terms or notices before participating in any such campaigns or promotions as you will be required to comply with them if you participate. Any additional privacy terms or notices will be made prominently available to you.