We understand that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, https://arthr.com/ (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with Our obligations and your rights under the law.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
|“Data Protection Legislation"||
has the meaning given in Paragraph 2.1;
has the meaning given in Paragraph 2.1;
2. What Is Personal Data?
2.2 Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
2.3 You can also get further information about data protection and privacy laws by visiting the Information Commissioner’s web site at: https://ico.org.uk/.
3. What Personal Data Do We Collect and How?
3.1 Purchasing products from us
When you order products from our online shop or over the phone we collect personal information about you to enable us to fulfil your order. The types of personal information we collect will include name, email address, delivery address and payment card information.
3.2 When you sign up for our e-newsletter, request information from us, or provide us with information
In our dealings with you, whether in person, by telephone, letter, email or webchat, you may directly provide us with various types of personal information, including your name and contact details such as your address, email address and telephone numbers. We may also collect personal information if we are communicating with you on social media sites such as Twitter, Facebook, Instagram or LinkedIn.
3.3 When you visit our website
When you visit our website we obtain personal information from your IP address and the operating system and web browser that you use. This enables us to compile statistical data on the use of our website which helps us to improve the user experience.
3.4 When you interact with us
If you join our ChangeMaker Community, complete one of our surveys, participate in our research, or attend any of our events, we will collect various types of personal information that you provide to us, which may include your name and contact details. Also, although we will not intentionally ask you for information regarding your health, if you provide us with information about products that you are interested in, your opinions about existing or proposed products, this may directly or indirectly reveal information about your health.
3.5 When you apply for a job
If you apply for a job with us you may provide us with personal information, including special category personal information. Your application directly to us, or via a recruitment agency, will constitute your consent to our use of this information. We will use the information to consider your application for a job with us. We may also use the information to carry out checks to verify the information provided by you (including reference, background and criminal record checks). We may disclose the information to recruiters, referees and your current and previous employers.
3.6 When you agree to receive marketing information
If you agree to receive marketing information your personal information may be stored in our contact database. If you no longer wish to receive any marketing emails from us you can unsubscribe at any time by using the "Unsubscribe" button on the email footer or by contacting email@example.com.
3.7 Third Party Data Providers
We will ensure that any data that we purchase is from a reputable source and has been collected and maintained in compliance with the data protection act 2018. We will contact you on the basis of it being within our legitimate interests.
We process name, address & telephone number from these third parties in order for us to contact you to hear about products or services that may be of interest.
3.8 When you visit the Site, We automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, We collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information”.
3.9 Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.
3.10 We collect Device Information using the following technologies:
- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
- “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.
3.12 Additionally when you make a purchase or attempt to make a purchase through the Site, We collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers, email address, and phone number. We refer to this information as “Order Information”.
3.14 When you sign up to the Arthr ChangeMaker programme you’ll be asked to participate in market research and product testing that will infer medical information about you in order to test products accurately. The information is held securely and is not used in any way other than for the purpose of the product you are testing. Details of the product testing feedback will not be held against your personal record but a non-identifiable number ID.
4. How Do We Use Your Personal Data?
4.1 We use the Order Information and the other information that We collect generally to fulfil any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, We use this Information to:
- communicate with you;
- screen Our orders for potential risk or fraud; and
- when in line with the preferences you have shared with us, provide you with information or advertising relating to Our products or services.
- to process and fulfil orders that you submit via our online shop
- to handle Customer Service enquiries about your order
- if you subscribe, to provide you with our e-newsletter, and any other information or support that you may request
- if you have opted in to receive marketing communications from us, to send you information about your products, research and events and other marketing material
- if you join our ChangeMakers Community or agree to participate in our research activities, to screen you for your suitability to assist with the design and testing of new products, to invite you to participate in ChangeMakers activities and our research, and then to send you information about the results
- if you have opted in to receive communications from us, to upload your contact details in a securely encrypted format to Facebook, Instagram, Twitter and LinkedIn. If these platforms determine that you have an account with them then we will invite you to connect with us on the platform. Whether or not you accept our invitation, we will show you marketing material and other information that we think will be of interest to you. Note that if any of the social media platforms do not recognise your contact details then your details are promptly deleted
- if you are applying for a job, to screen you against other applicants and to contact you in connection with your application
- to process and respond to your requests for information, or to enquiries or complaints received from you
4.3 Under the Data Protection Legislation, We must always have a lawful basis for using personal data. Accordingly we will therefore only process your personal information if:
- it is necessary for the performance of a contract with you
- it is necessary in connection with a legal obligation
- you have given your consent (where necessary) to such use
- if we or a third party have a legitimate interest which is not overridden by your interests or your rights and freedoms
4.4 With your permission and/or where permitted by law, We may also use your personal data for marketing purposes, which may include contacting you by email AND/OR telephone AND/OR text message AND/OR post with information, news, and offers on Our products AND/OR services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with Our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time. Third Parties whose content appears on Our Site may use third-party Cookies, as detailed below in Paragraph 13. Please refer to Paragraph 13 for more information on controlling cookies.
4.5 Please note that We do not control the activities of such third parties, nor the data that they collect and use themselves, and We advise you to check the privacy policies of any such third parties. You can opt out of targeted advertising by clicking on the following links:
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/ .
4.6 We will only use your personal data for the purpose(s) for which it was originally collected unless We reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If We do use your personal data in this way and you wish Us to explain how the new purpose is compatible with the original, please contact Us using the details in Paragraph 15.
4.7 We need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, We will inform you and explain the legal basis which allows Us to do so.
4.8 In some circumstances, where permitted or required by law, We may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
5. How Long Will You Keep My Personal Data?
When you place an order through the Site, We will maintain your Order Information for Our records unless and until you ask us to delete this information. We will not keep your Personal Data for any longer than is necessary in light of the reason(s) for which it was first collected.
6. How and Where Do You Store or Transfer My Personal Data?
We will only store your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation.
We will only store your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.
7. Sharing Your Personal Data
7.1 We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.
- We share your Personal Data with third parties to help us use your Personal Data, as described above. For example, We use Shopify to power Our online store--you can read more about how Shopify uses your Personal Data here: https://www.shopify.com/legal/privacy
- We also use Google Analytics to help us understand how Our customers use the Site--you can read more about how Google uses your Personal Data here: https://www.google.com/intl/en/policies/privacy/.
- You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
- We use a third-party logistics supplier to process and fulfil Our orders (Redpanda Fulfilment Ltd).
- If any of your personal data is shared with a third party, as described above, We will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, Our obligations, and the third party’s obligations under the law, as described above in paragraph 5.
- If any of your Personal Data is transferred outside of the UK, We will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in paragraph 5.
- In some limited circumstances, We may be legally required to share certain personal data, which might include yours, if We are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
7.2 As described above, We use your Personal Data to provide you with targeted advertisements or marketing communications We believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
8. Do Not Track
Please note that We do not alter Our Site’s data collection and use practices when We see a Do Not Track signal from your browser.
9. Your Rights
9.1 If you are a European resident please note that We are processing your information in order to fulfil contracts We might have with you (for example if you make an order through the Site), or otherwise to pursue Our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.
- 9.2 If you are a European resident, you have the right to access personal information We hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right. More particularly, under the Data Protection Legislation, you have the following rights, which We will always work to uphold:
- The right to access the personal data We hold about you. Paragraph 12 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Paragraph 15 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that We hold. Please contact us using the details in Paragraph 15 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to withdraw consent. This means that, if We are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- The right to data portability. This means that, if you have provided personal data to us directly, We are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
9.3 For more information about Our use of your personal data or exercising your rights as outlined above, please contact us by using the details provided in Paragraph 15.
9.4 It is important that your personal data is kept accurate and up-to-date. If any of the personal data We hold about you changes, please keep us informed as long as We have that data.
9.5 Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
9.6 If you have any cause for complaint about Our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Paragraph 15.
10. How Can I Control My Personal Data?
10.1 In addition to your rights under the Data Protection Legislation, set out in Paragraph 9, when you submit personal data via Our Site, you may be given options to restrict Our use of your personal 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 OR 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. Can I Withhold Information?
11.1 You may access certain areas of Our Site without providing any personal 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 Can I Access My Personal Data?
12.1 If you want to know what personal data We have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
12.2 All subject access requests should be made in writing and sent to the email or postal addresses shown in Paragraph 15.
12.3 There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover Our administrative costs in responding.
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if We change Our business in a way that affects Personal Data protection.
15. Contact Us
For more information about Our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by email at firstname.lastname@example.org.