Baby Smiles Club is committed to safeguarding the privacy of the personal information that is provided to us, or collected by us, during the course of our operation, as well as the personal information we receive from visitors to our website or our social media channels.
This Privacy Notice explains how we may collect and use any personal information that we obtain about you and your rights in relation to that information. It is based on European Union data protection principles that are set out in the General Data Protection Regulation. Baby Smiles Club is a global operation; if you are in a jurisdiction that has significantly different data protection laws, it may be that certain of the rights and obligations in this Privacy Notice do not apply to you. We may provide you with additional privacy notices where appropriate. Any such notices supplement and should be read together with this Privacy Notice.
Our website and social media channels are not intended for use by children. Unless prompted by us, please do not provide us with any personal information (including photographs or videos) about your children, either directly or indirectly (for example by posting personal information about your children on our social media channels). Any information provided about your children should be anonymised, unless otherwise prompted by us.
1.1. We are committed to safeguarding the privacy of our website visitors and individual customers.
1.2. This Privacy Notice applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
1.3. Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the collection, sharing and publication of your personal data.
1.4. In this policy, "we", "us" and "our" refer to Baby Smiles Club.
2. The personal data that we collect
2.1. In this Section 2 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.
2.2. We may process data enabling us to get in touch with you ("contact data"). The contact data may include your name, email address, telephone number, postal address and social media account identifiers. The source of the contact data is you.
2.3. We may process your website user account data ("account data"). The account data may include your account identifier, name, email address, business name, account creation and modification dates, website settings and marketing preferences. The primary source of the account data is you, although some elements of the account data may be generated by our website.
2.4. We may process your information included in your personal profile on our website ("profile data"). The profile data may include your name, address, telephone number, email address, profile pictures, gender and date of birth. The source of the profile data is you.
2.5. We may process your personal data that are provided in the course of the use of our services and generated by our services in the course of such use ("service data"). The source of the service data is you and/or our services.
2.6. We may process information relating to transactions, including purchases of products and/or services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data is you and/or our payment services provider.
2.7. We may process information contained in or relating to any communication that you send to us or that we send to you ("communication data"). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.
2.8. We may process data about your use of our website, products and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.
2.9. Please do not supply any other person's personal data to us (including personal data relating to your children), unless we prompt you to do so.
3. Purposes of processing and legal bases
3.1. In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.
3.2. Operations - We may process your personal data for the purposes of operating our website, the processing and fulfilment of orders, providing our services, supplying our products, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business.
3.3. Publications - We may process account data, profile data and/or service data for the purposes of publishing such data on our website and elsewhere through our services in accordance with your express instructions. The legal basis for this processing is our legitimate interests, namely the publication of content in the ordinary course of our operations.
3.4. Relationships and communications - We may process contact data, account data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, individual customers, the maintenance of our relationships, enabling the use of our services, and the proper administration of our website, services and business.
3.5. Direct marketing - We may process contact data, account data, profile data, and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email, SMS and/or post and making contact by telephone for marketing-related purposes. The legal basis for this processing is our legitimate interests, namely promoting our business and communicating marketing messages and offers to our website visitors and individual customers.
3.6. Research and analysis - We may process usage data, service data and/or transaction data for the purposes of researching and analysing the use of our website, products and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.
3.7. Record keeping - We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this Privacy Notice.
3.8. Security - We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
3.9. Insurance and risk management - We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.10. Legal claims - We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.11. Legal compliance and vital interests - We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
4. Providing your personal data to others
4.1. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice.
4.2. Your personal data held in our website database will be stored on the servers of our hosting services providers.
4.3. Financial transactions relating to our website, products and services are handled by our payment services provider, Stripe Payment Ltd. We will share transaction data with our payment services provider only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services provider’s privacy policies and practices at stripe.com.
4.4. In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. Retaining and deleting personal data
5.1. This Section 5 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3. The length of time for which we will retain your personal data depends on the type of personal data that it is. In general, this will be for a maximum of six years after you have ceased to become a customer of us. If you have any questions about retention periods, please contact us at [email protected].
5.4 If you grant to us a licence to publish any of your personal data, we may continue to retain and publish that personal data after the end of the relevant retention period in accordance with the applicable licence terms, subject to your data subject rights. If we cease to publish such personal data after the end of the relevant retention period specified in this Section 5, that personal data will be retained in accordance with the rest of this Section 5.
5.5. Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6. Security of personal data
6.1. We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
6.2. We will store your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
6.3. The following personal data will be stored by us in encrypted form: your name, contact information and password(s).
6.4. Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
6.5. You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
6.6. You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website and products confidential and we will not ask you for your password (except when you log in to our website).
7. Your rights
7.1. In this Section 7, we have listed the rights that you have under data protection law.
7.2. Your principal rights under data protection law are:
7.2.1. the right to access - you can ask for copies of your personal data;
7.2.2. the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
7.2.3. the right to erasure - you can ask us to erase your personal data;
7.2.4. the right to restrict processing - you can ask us to restrict the processing of your personal data;
7.2.5. the right to object to processing - you can object to the processing of your personal data;
7.2.6. the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
7.2.7. the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
7.2.8. the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
7.3. These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
7.4. You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
8. Third party websites
8.1. Our website may include hyperlinks to, and details of, third party websites.
8.2. In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.
9. Personal data of children
9.1. Our website, products and services are targeted at persons over the age of 18.
9.2. If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
10. Updating information
Please let us know if the personal information that we hold about you needs to be corrected or updated.
We may update this Privacy Notice from time to time by publishing a new version on our website.
12. Data protection officer
Our data protection officer's contact details are [email protected].
Last updated: 12 August, 2020