Everybodysmile Ltd understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits these websites, everybodysmile.co.uk and everybodysmile.biz (“Our Sites”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
1. DEFINITIONS AND INTERPRETATION
1.1 In this Policy, the following terms shall have the following meanings:
1.1.1 “personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
1.1.2 “We/Us/Our” Means Everybodysmile Ltd, a limited company registered in England under company number 3671724, whose registered address is 20 High Street, Lewes, East Sussex, BN7 2LN, and whose main trading address is PO Box 259, Burgess Hill, West Sussex, RH15 9ZR.
2. INFORMATION ABOUT US
2.1 Our Site is owned and operated by Everybodysmile Ltd, a limited company registered in England under company number 3671724, whose registered address is 20 High Street, Lewes, East Sussex, BN7 2LN and whose main trading address is PO Box 259, Burgess Hill, West Sussex, RH15 9ZR.
2.2 Our VAT number is 759648468.
2.3 Our Data Protection Officer is Lisa Adams, and can be contacted by email at firstname.lastname@example.org or by post at PO Box 259, Burgess Hill, West Sussex, RH15 9ZR.
3. WHAT DOES THIS POLICY COVER?
4. YOUR RIGHTS
4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the personal data We hold about you (see section 12);
4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 13);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you. Please contact Us using the details in section 13 to request this;
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to Us using your personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.
4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 13 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5. WHAT DATA DO WE COLLECT?
Depending upon your use of Our Site, We may collect some or all of the following personal and non-personal data:
5.2 business/company name;
5.3 contact information such as email addresses and telephone numbers;
5.4 business/postal address;
5.5 demographic information such as post code;
5.6 IP address;
5.7 web browser type and version;
5.8 operating system;
5.9 information relating to orders placed through our ordering system such as image references, products ordered, prices and special requirements.
6. HOW DO WE USE YOUR DATA?
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
6.2.1 Supplying Our products and services to you (please note that We require your personal data in order to enter into a contract with you);
6.2.2 Personalising and tailoring Our products and services for you;
6.2.3 Replying to emails from you;
6.2.4 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by following the unsubscribe links provided in the footer of the email;
6.3 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 with information, news, and offers on Our products and services. 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 GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
6.4 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
6.5 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following basis):
6.5.1 Your data will be held indefinitely to allow us to maintain accurate historical records of transactions through our systems for our products and services.
7. HOW AND WHERE DO WE STORE YOUR DATA?
7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
7.1.1 Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.
7.2 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
8. DO WE SHARE YOUR DATA?
8.1 We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing and delivery of goods. Your data will be made available to the photographer whose images you are viewing. 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.
8.2 We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR including:
8.3 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
9. WHAT HAPPENS IF OUR BUSINESS CHANGES HANDS?
9.2 In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.
10. HOW CAN YOU CONTROL YOUR DATA?
10.1 In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (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).
10.2 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.
11. YOUR RIGHT TO WITHOLD INFORMATION
11.1 You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
12. HOW YOU CAN ACCESS YOUR DATA
12.1 You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact using the contact details below in section 13.
13. CONTACTING US