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                                                        BOWENFORYOURBODY

1. Introduction

This privacy notice explains in detail the types of personal data we may collect about when you interact with us. It also explains how we will store and handle that data, and keep it safe.

We may need to update this Privacy Notice from time to time, and we will notify you of any significant changes via email and you can check it whenever you wish. 

When you using the Bowenforyourbody website, Bowenforyourbody is the data controller.  

2. Explaining the legal bases we rely on

We may collect data for several reasons as the law on data protection sets out the reasons a company may collect and process your data, including;

Consent; in specific situations, we can collect and process your data with your consent, for example when you tick a box to receive email newsletters. 

When collecting your personal data, we will always make it clear to which data is necessary in connection with a particular service.

Contractual Obligations; when you place an order with us, we will need your personal data, such as name and address to comply with our contractual obligations, to deliver your purchase, and to pass them onto our chosen courier service. 

Legal Compliance; if the law requires us to, we may need to collect and process your data. For example, we can pass on details of people involved in fraud of other criminal activity affecting Bowenforyourbody. 

Legitimate Interest; in specific circumstances, we require your data to pursue our legitimate interest in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. 

For example, we will send you or make available personalised offers based on your purchase history.  When you shop with us, we will also send you direct marketing emails if you do not 'opt-out'.  This is referred to as a 'soft opt-in'. 

We will also combine the shopping history of many customers to  identify trends and ensure we can keep up with demand, and this will help us with new products. 

We will also use your email address to send you direct marketing information by email, telling you about products that we think might interest you. We will also send you direct marketing emails when you shop with us, this is called a 'soft opt -in'. 

With your consent or when you shop with us, and do not choose to 'opt -out' from receiving our emails  ( this is known as a  'soft opt-in'.

 We may also contact you regarding market research. 

We will also send you direct marketing emails when you shop with us and do not choose to opt -out , this is referred to as a 'soft opt -in'. 

With your consent, or when you shop with us and do not choose to opt out from receiving our emails ('soft opt in') we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text,  about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on. This is only applicable in the UK.

3. When do we collect your personal data? 

• When you visit any of our websites, and use your account to buy products, or redeem vouchers from BowenforyourBody at a pop up  shop or online.
• When you make an online purchase and check out as a guest (in which case we just collect transaction-based data).
• When you create an account with us.
• When you shop online, we capture information through cookies and similar technologies, you can manage these when you visit our site.
• When you purchase a product at a pop up event or by phone but don’t have (or don’t use) an account.
• When you engage with us on social media.
• When you download or install one of our apps.
• When you contact us by any means with queries, complaints etc
• When you enter prize draws or competitions.
• When you choose to complete any surveys we send you. 
• When you comment on or review our products and services.
• We collect data from publicly-available sources when you have given your consent to share information or where the information is made public as a matter of law.

5. What sort of personal data do we collect?

• If you have a web account with us: your name, gender, date of birth, billing/delivery address, orders and receipts, email and telephone number. For your security, we’ll also keep an encrypted record of your login password.
• Details of your interactions with us through the BowenforyourBody email, by telephone or by using one of our apps. For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made, items viewed or added to your basket, voucher redemptions, items you show interest in, web pages you visit and how and when you contact us.
• Details of your shopping preferences.
• Details of your visits to our websites or apps, and which site you came from to ours.
• Information gathered by the use of cookies in your web browser.
• Open rates, click through rates on email marketing campaigns through the use of Pixels
• Personal details which help us to recommend items of interest.
• We’ll only ask for and use your personal data collected for recommending items of interest and to tailor your shopping experience with us. Of course, it’s always your choice whether you share such details with us. 
• Payment card information.
• Your comments and product reviews. 
• To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered.
• Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.

6. How and why do we use your personal data?

We use your data to offer you promotions, products and services that are most likely to interest you.

The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.

If you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.

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

For example, if you’ve asked us to let you know when an item comes back into stock, we can’t do that if you’ve withdrawn your general. 

For example, if you’ve asked us to let you know when an item comes back into stock, we can’t do that if you’ve withdrawn your general consent to hear from us.

Here’s how we’ll use your personal data and why:

• To process any orders that you make by using our websites, apps or in store. If we don’t collect your personal data during checkout, we won’t be able to process your order and comply with our legal obligations.
• To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience. 
• To send you email notifications when you place a product in your basket and you abandon your browsing before completing your checkout. We do this based on our legitimate interest. To provide you with tracking information so that you can follow your order. We do this under legitimate interest to enhance your customer experience and give you more information around where your delivery is and when your order will arrive.
  ◊To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience. 
• To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interestTo respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience. 
• To send you email notifications when you place a product in your basket and you abandon your browsing before completing your checkout. We do this based on our legitimate interest. To provide you with tracking information so that you can follow your order. We do this under legitimate interest to enhance your customer experience and give you more information around where your delivery is and when your order will arrive.
• To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest. For example, by checking your password when you login and using automated monitoring of IP addresses to identify possible fraudulent log-ins from unexpected locations.
• With your consent, or whenever you purchase with us and do not choose out of receiving our updates, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone and through our contact centres about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on. This is only applicable within the UK.

You are free to opt out of hearing from us by post at any time.

• To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
• To display the most interesting content to you on our websites or apps, we’ll use data we hold about your favourite brands or products and so on. We do so on the basis of your consent to receive app notifications and/or for our website to place cookies or similar technology on your device.  If not through the use of cookies or similar technology, then on the basis of our legitimate interest.
  

For example, we might display a list of items you’ve recently looked at, or offer you recommendations based on your purchase history and any other data you’ve shared with us.

• To comply with our contractual or legal obligations to share data with law enforcement.

For example, when a court order is submitted to share data with law enforcement agencies or a court of law.

 How we protect your personal data

We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.

We secure access to all transactional areas of our websites and apps using ‘https’ technology.

Access to your personal data is password-protected, and sensitive data (such as payment card information) is secured and encrypted to ensure it is protected.

. How long will we keep your personal data?

Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.

At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.

Some examples of customer data retention periods: 

Orders

When you place an order, we’ll keep the personal data you give us for for five years so we can comply with our legal and contractual obligations.

Who do we share your personal data with? 

We sometimes share  your details with our courier service., or for fraud management, to handle complaints, to help us personalise our offers to you and so on.

Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:

• We provide only the information they need to perform their specific services.
• They may only use your data for the exact purposes we specify in our contract with them.
• We work closely with them to ensure that your privacy is respected and protected at all times.
• If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
  

Examples of the kind of third parties we work with are:

• IT companies who support our website and other business systems.
• Operational companies such as delivery couriers to contact you about your order delivery & occasionally service review messages
• Google/Facebook to show you products that might interest you while you’re browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our websites.

We will only do this in very specific circumstances, for example:

For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.

We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.

To help personalise your experience with Bowenforyourbody website we currently use the following companies, who will process your personal data as part of their contracts with us

• Google
• Twitter
• Instagram
• Godaddy website builder 
• TikTok 

. Where your personal data may be processed

BowenforyourBody is a UK based company and so we will transfer your data to the UK, which is outside of the EU. We may also need to share your personal data with third parties and suppliers outside the European Economic Area (EEA).

The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data processors in countries that are outside the UK. For example, this might be required in order to fulfil your order, process your payment details or provide support services.

If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed in the UK. For example, our contracts with third parties stipulate the standards they must follow at all times. 

Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.

What are your rights over your personal data?

You have the right to request:

• Access to the personal data we hold about you, free of charge in most cases.
• The correction of your personal data when incorrect, out of date or incomplete.
• The deletion of the data we hold about you, in specific circumstances; for example, when you withdraw consent or object, and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as the end of a warranty). 
• A computer file in a common format (CSV or similar) containing the personal data that you have previously provided to us, and the right to have your information transferred to another entity where this is technically possible.
• Restriction of the use of your personal data, in specific circumstances, generally while we are deciding on an objection you have made. 
• That we stop processing your personal data, in specific circumstances; for example, when you have withdrawn consent, or object for reasons related to your individual circumstances.
• That we stop using your personal data for direct marketing (either through specific channels, or all channels).
• That we stop any consent-based processing of your personal data after you withdraw that consent.
• You can contact us to request to exercise these rights at any time by emailing us at info@bowenforyourbody.co.uk and we will send the relevant form to complete.
• If we choose not to action your request, we will explain the reasons for our refusal. 

Your right to withdraw consent

Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.

Where we rely on our legitimate interest

In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data, such as administration  of an extended warranty.

Direct marketing

You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.

Checking your identity

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. 

If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

 How can you stop the use of your personal data for direct marketing?

There are several ways you can stop direct marketing communications from us:

• Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails from that particular division.
• If you have an account, log in into your johnlewis.com or waitrose.com account, visit the ‘My Account’ area and change your preferences.
• Write to BowenforyourBody, Chandos Business Centre,87 Warwick Place, Leamington Spa, Warwickshire, CV32 4RJ
• Please bear in mind that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated..

Contacting the Regulator

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO) or those of the Office of the Data Protection Authority (ODPA) for Guernsey and the Jersey Office of the Information Commissioner (JOIC) for Jersey. 

You can contact the ICO by calling 0303 123 1113
Or go online to ico.org.uk/concerns (opens in a new window; please note we can't be responsible for the content of external websites)

You can also contact the ICO at the following address:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF