Privacy Policy

Introduction

We are Safe Orchard, a trading name of Keith Parsons who is the operator of the Safe Orchard website at: Keith Parsons, Third Floor, 3 Hill Street, Edinburgh, EH2 3JP. This privacy policy will inform you as to how we collect, look after and otherwise process your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. Our website and services are not intended for children, and we do not knowingly collect data relating to children. Please read this privacy policy so that you are fully aware of how and why we collect and use your personal data.

Keith Parsons is the controller and responsible for your personal data. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us by email at: hello@safeorchard.com.

We keep our privacy policy under regular review and any changes we make to it will be, where appropriate, notified to you by email.

The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (this is anonymous data).

We may collect, use, store and transfer the following personal data about you:

Identity Data including your first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data including your billing address, delivery address, email address and telephone numbers.
Financial Data including your bank account and payment card details.
Transaction Data including details about payments to and from you and other details of products and services you have purchased from us.
Technical Data including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Profile Data including your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
Usage Data including information about how you use our website, products, and services.
Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you provide information to us about any person other than yourself, your employees, counterparties, your advisers or your suppliers, you must ensure that they understand how their information will be used, and that they have given their permission for you to disclose it to us and for you to allow us, and our outsourced service providers, to use it.

How We Collect Your Personal Data

Generally, we collect your personal data directly from you – in person, by post, phone, email or otherwise. This may occur when you:

seek or purchase our products or services;
respond to our direct marketing;
request marketing to be sent to you;
enter a competition, promotion, or survey; or
give us feedback or contact us.

We may also collect information about you indirectly, including:

Technical Data from analytics providers such as Google, based outside the UK;
Technical Data from advertising networks such as Google, Bing and Facebook based outside the UK;
Technical Data from search information providers based inside and outside the UK;
Contact, Financial and Transaction Data from providers of technical, payment and delivery services;
Identity and Contact Data from data brokers or aggregators; and
Identity and Contact Data from publicly available sources.

How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

where we need to perform the contract, we are about to enter into or have entered into with you;
where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
where we need to comply with a legal obligation; or
where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for Which We Will Use Your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you
To process and deliver your order including: (a) Manage payments, fees, and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) 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	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) 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 website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) 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) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	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 website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	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	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Promotional Communications

We may use your personal information to send you updates (by email, text message, telephone or post) about our products and/or services, including exclusive offers, promotions or information about new products and/or services.

We have a legitimate interest in processing your personal information for promotional purposes (see above). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will not sell your personal information to or share it with other organisations for marketing purposes, except where we remain the controller of your personal information and share it with third parties who act as a data processor on our behalf and only process the personal information on our instructions and for the purposes set out above.

You have the right to opt out of receiving promotional communications at any time by emailing us, using the ‘unsubscribe’ link in emails, or updating your marketing preferences in your user profile on our website. We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.

Who We Share Your Personal Data With

We routinely share personal information with service providers we use to help deliver products and/or services to you, such as security providers, payment service providers, warehouses and delivery companies. We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you.

We may also share your personal data with:

social media companies and our advertising partners. For example, we might match your email address with Facebook and Twitter to enable us to run promotions on their platforms;
our professional advisors such as our lawyers or auditors when they need to give us their professional advice; or
public authorities, agencies and other government bodies. We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

How Long Your Personal Information Will Be Kept

We will keep your personal information while you have an account with us or we are providing products and/or services to you. Thereafter, we will keep your personal information for as long as is necessary:

to respond to any questions, complaints or claims made by you or on your behalf;
to show that we treated you fairly; and
to keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. If you want to learn more about our specific retention periods for your personal information, please contact us.

When it is no longer necessary to retain your personal information we will securely destroy your personal information in accordance with applicable laws and regulations. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

International Transfers of Your Personal Information

We do not generally transfer your personal information abroad.

If, to deliver our services to you, it is necessary for us to share or transfer your personal information outside the United Kingdom, then some additional safeguards will apply.

Where we need to make a transfer of this nature, we will only do so if such a transfer is safe and your personal information will be secure.

This means that when we transfer your personal information outside the UK we will only do so where (i) there are binding corporate rules in place; or (ii) the country where we are making the transfer to is a country deemed by the UK Information Commissioner’s Office to have an adequate level of protection in place for your personal information; or (iii) if there is no adequacy decision, where we have a lawful contractual arrangement with the service provider containing protections for your personal information (i.e. an international data transfer agreement).

Please contact us if you want further information on the mechanisms used by us when transferring your personal information out of the UK.

Your Rights

Under the applicable data protection laws you have a number of rights, as set out below:

Right to access your personal information. You may request confirmation that we hold personal information about you, as well as access to a copy of any such data.
Right to rectification. You may ask us to correct any inaccurate information we hold about you.
Right to erasure (or Right to be forgotten). You may, in certain circumstances, ask us to delete your personal information.
Right to restriction. You may ask us to restrict the processing of your personal information if (i) you want us to establish the accuracy of the information, (ii) where our use of the information is unlawful but you do not want us to erase it, (iii) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims, or (iv) you have objected to our use of your personal information but we need to verify whether we have overriding legitimate grounds to use it.
Right to portability. You may request the receipt of the personal information that you have provided to us, in a structured, commonly used and machine-readable form, or its transfer to another organisation.
Right to object. You may object to our processing of your personal information (i) at any time when your personal information is being processed for direct marketing, or (ii) 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Right not to be subject to automated individual decision making. You have the right not be subject to a decision based solely on automated processing (or profiling) that produces legal effects concerning you or similarly significantly affects you.
Right to withdraw consent. Where our processing of your personal information is based on your consent, you may withdraw this consent at any time, although this will not affect the lawfulness of any prior processing where we relied on your consent.
Right to make a complaint. You may make a complaint about our processing of your personal information by contacting us via the contact details set out in this privacy policy. While we hope that we would be able to address any issues you have in respect of this processing, you may also make a complaint to the UK’s data protection regulator (see below).

For further information on each of these rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation available via the following link: https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/individual-rights/individual-rights/ .

If you would like to exercise any of these rights, please contact us using our contact details set out below.

You will not have to pay a fee to access your data or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Keeping Your Personal Information Secure

We have put in place appropriate security measures to prevent personal information from being accidentally lost, used or accessed unlawfully, altered or disclosed. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to Complain

We hope that we can resolve any query or concern you may raise about our use of your personal information.

The UK General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, the Information Commissioner, who may be contacted at: https://ico.org.uk/concerns or telephone: 0303 123 1113.