Welcome to BooBerry’s privacy policy. BooBerry respects your privacy and is committed to protecting your personal data.

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1. INTRODUCTION

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This privacy policy tells you how BooBerry uses your personal data when you visit our website or interact with us, including when you sign up to our newsletter, use our products and services or take part in a competition.

It also tells you your privacy rights and how the law protects you.

It is important that you read this privacy policy, together with any other privacy notices we may show you from time to time, so that you are fully aware of how and why we are using your personal data.

This website is not intended for children and we do not knowingly collect data relating to children.

This privacy policy was last updated on 7th October 2019.

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2. WHO WE ARE

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The mission of BooBerry is to revolutionise how you do your makeup. You can read more about us here.

BooBerry is the data controller responsible for this website. Being the data controller means we are responsible for deciding why and how we use personal data in our business.

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3. HOW WE COLLECT DATA

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There are lots of different ways in which we may collect data, or receive data, and you can see an explanation of the main ways below.

You may give us data when you interact with us

You may give us data by filling in forms or by corresponding with us by post, phone, email or through chat or social media. This includes data you provide when you:

• sign up to receive our newsletter

• make enquiries or request information be sent to you

• create an account on our website

• order our products

• ask for direct marketing to be sent to you

• use ‘refer a friend’

• participate in our forum

• engage with us on social media

• enter a competition, promotion or survey

• contact customer services or

• leave comments or reviews on our products or services

We may get some data automatically

As you interact with us, including via the BooBerry website, we may automatically collect data about your equipment, browsing actions and patterns. We may also collect data when you click on one of our adverts (including those shown on third party websites or via social media). 

We may obtain some data from third parties

We may receive data about you from various categories of third parties, including:

• from providers of services which facilitate our ecommerce operations, including ecommerce platforms and payment and fraud prevention services;

• from analytics providers, advertising networks and search information providers; from data partners;

• from your friends who referred you using ‘refer a friend’;

• from publicly available sources; and from any third parties who are permitted by law or have your permission to share your personal data with us, such as via social media or review sites.

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4. TYPES OF PERSONAL DATA WE COLLECT

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How we collect data above described all the different ways in which it’s possible to be given or obtain data. Some of that data may be personal data and we explain below the types of personal data we may collect about you. Of course, the types of personal data we collect about you will depend on how you are interacting with us.

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 (anonymous data).

We collect a variety of personal information about our customers and visitors to the BooBerry website.

This personal data falls into these categories:

• Identity Data includes title, gender, first name, maiden name, last name, date of birth, username or similar identifier and your login/password. If you interact with us through social media, this may include your social media user name.

• Contact Data includes billing address, delivery address, email address and telephone numbers.

• Financial Data includes payment card and direct debit/bank account details.

• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses, as well as any profile data which we have added (for example, using analytics and profiling).

• Technical Data includes 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.

• Usage Data includes information about how you use our website, products and services, and any of the content you contribute to the forum.

• Tracking Data includes information we or others collect about you from cookies and similar tracking technologies, such as web beacons, pixels, and mobile identifiers.

• Marketing and Communications Data includes your preferences in receiving direct marketing from us and our third parties and your communication preferences. 

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

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 share personal data referred to in this category we will not know and can only treat it as personal data. If you post any of this data on the forum, you have chosen to make it public online, and anyone can read it.

Remember, if you choose not to share personal data with us, or refuse certain contact permissions, we might not be able to provide the products and services you’ve asked for.

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5. EXPLAINING THE LEGAL BASES FOR USING PERSONAL DATA

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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. For example, when you purchase our products, that’s a contract between you and us for us to supply the products to 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. For example, fraud screening as part of the check-out process or keeping our website secure.

• Where we need to comply with a legal or regulatory obligation. For example, keeping records of our sales for tax compliance.

Generally, we do not rely on consent as a legal basis for processing your personal data other than where the law requires it, for example in relation to sending certain direct marketing communications. Where our legal basis is consent, you have the right to withdraw consent at any time.

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 6. COOKIES

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A cookie is a small file of letters and numbers that we store via your browser.

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

We use the following categories of cookies:

• Strictly necessary cookies. These are cookies which are needed to make the website work properly. They include, for example, cookies that enable you to log in, use a shopping cart or make secure payments.

• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region). These also allow us to tell if you’ve left any products in your basket without checking out.

• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website relevant to your interests and for advertising and retargeting purposes. We may also share this information with third parties for this purpose.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

Please be aware that if you delete your cookies, two things will happen:

• We will no longer know that you've opted out of online behavioural advertising, so our adverts will still appear to you on other websites.

• We will no longer automatically recognise any website preferences that you have set.

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7. DISCLOSURES OF YOUR PERSONAL DATA

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We may share your personal data with the third parties set out below for the purposes set out in this privacy policy. We may also share your personal data if the law otherwise allows it.

We may share personal data with the following categories of third parties:

• suppliers and service providers (such as outsourced services partners, technology service providers, manufacturers and post and courier services)

• payment services providers, via Stripe – payment processors may take your personal data directly from you as part of processing a purchase, and they will be data controllers in their own right for that processing

• auditors and professional advisers like bankers, lawyers, accountants and insurers and

• government, regulators and law enforcement

We share personal data with the following specific third parties:

• WIX, who are the ecommerce platform we use for our website. The WIX privacy policy tells you all the details you need to know about what information WIX collect from you when you use our website or buy a BooBerry product, and how WIX may use and share it when we use them to support us with processing orders, risk and fraud screening, authentication and payments. You can read the full WIX privacy here; in particular see the section about Information from buyers. WIX also carries out some automated decision making, for example screening IP addresses or payment information to block potentially fraudulent transactions for a short period of time. If you have any questions about the WIX privacy policy you can contact them directly.

We also share data with third parties connected to advertising, retargeting and analytics. Please see Cookies above, including the cookie list, for more information about who those third parties are.

Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

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.

 

 

8. DATA SECURITY

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We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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.

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

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9. DATA RETENTION

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We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

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10. HOW TO CONTACT BOOBERRY ABOUT PRIVACY

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If you have any questions about this privacy policy, or would like to exercise any of your rights, please email us at info@booberry.co.uk.

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If you need help about our products and services, or this website generally, please contact us here.

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11. THIRD-PARTY LINKS

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This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit. 

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12. IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

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13. CHANGE OF PURPOSE

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 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. 

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14. 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

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 your personal data

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

This enables you to 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 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 transfer of your personal data

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.

• Right to withdraw consent

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.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data 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.

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15. FINALLY, A SMALL REQUEST FROM BOOBERRY

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

 

© BooBerry Limited 2020