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Privacy Notice and Cookies Policy

Horopito Limited (trading as “To Better Days”) (we or us) is a company registered in England and Wales under company number 10984513. Our registered office is at 82 St John Street, London, United Kingdom, EC1M 4JN.

Our contact details are [email protected].

  • What is the purpose of this document?

We are committed to protecting and respecting your privacy. This privacy notice sets out the basis on which any personal data we collect about users of our website at tobetterdays.co.uk(our site) and how that information will be processed by us.

This privacy notice applies to: visitors to our site who do not register as well as those who do; any customers that purchase our goods and/or services from us via our site or otherwise; and all individual contractors and service providers who provide services to our business (you).

We are a data controller. This means that we are responsible for deciding how we hold and use personal information about you, and for explaining this clearly to you.

Please read this privacy notice carefully to understand what we do with your personal information and what rights you have in relation to our activities.

Our site is not intended for children and we do not knowingly collect data relating to children.

  1. What is personal data and our lawful basis for processing
    1. Personal data, or personal information, means any information relating to an individual from which that person can be identified. There are special categories of more sensitive personal information which require a higher level of protection (see further at section 3.4, below).
  2. We will only use your personal information when the law allows us to. Our principle lawful basis for processing is set out in the table below. However, some of our grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
  3. We may only rely on our legitimate interests (or those of a third party) to process your personal information, if your interests and fundamental rights do not override those interests. Where we rely on legitimate interests for our processing, we have set out the relevant interest, below.

Generally, we do not rely on consent as a legal basis for processing your personal data although, if you are a private individual, 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.

  1. We will only use your personal information 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 information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
  2. Please note that we may process your personal information without your knowledge or consent where this is required or permitted by law.

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.

  • 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 (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender...

Contact Data includes billing address, delivery address, email address and telephone numbers.. Financial Data includes bank account and payment card details.

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

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.

Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

Usage Data includes [information about how you use our website, products and services.

Marketing and Communications Data includes your preferences in receiving 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 could be derived from your personal data but is not considered personal data in law as this data will 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.

As part of our usual course of business, 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. However, we may process information:

  1. Relating to a health condition or disability in order to meet our legal obligation to make reasonable adjustments in the provision of our services;
  2. To ensure meaningful equal opportunity and diversity and inclusion monitoring and reporting;
  3. Where it is needed to protect your vital interests (or someone else’s interests) and you are not capable of giving your consent;
  4. Where it is necessary to establish, exercise or defend a legal claim;
  5. Where you have manifestly made the information public; or
  6. Otherwise with your explicit consent.
  7. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  1. purchase our products or services;
  2. create an account on our website;
  3. subscribe to our service or publications;
  4. request marketing to be sent to you;
  5. enter a competition, promotion or survey; or
  6. give us feedback, make a complaint or contact us.

We collect Identity, Contact, Profile and Technical Data from our Social Media accounts:

  1. Facebook – @tobetterdays
  2. @tobetterdaysNAME/https://www.twitter.com/NAME technologies or interactions. As you interact with our website, we will automatically collect Usage and Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.] Please see section 10, below, for further details.Third parties or publicly available sources. We will receive personal data about you from various third parties [and public sources] as set out E]:
  3. Technical Data from the following parties:
  4. analytics providers [such as Google based outside the EU];

advertising networks based [inside OR outside] the EU]; andsearch information providers based [inside OR outside] the EU].We collect Identity, Contact and Profile Data from third parties with which we carry out joint events or promotions.Purposes for which we will use your personal data

Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interest
To register you as a new customer(a) Identity Data

 

(b) Contact Data

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 Data

 

(b) Contact Data

(c) Financial Data

(d) Transaction Data

(e) Marketing and Communications Data

(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 Data

 

(b) Contact Data

(c) Profile Data

(d) Marketing and Communications Data

(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)

f you voluntarily provide special category data to us in communications we will process such information solely for the purpose of responding to your communications and retaining our internal records of such correspondence.Special Category DataWe treat infoimratin that you provide top us voluntarily as information that you have manifestly made this information public to us; or

 

We process this information with your Consent

To enable you to partake in a prize draw, competition or complete a survey(a) Identity Data

 

(b) Contact Data

(c) Profile Data

(d) Usage Data

(e) Marketing and Communications Data

(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 Data

 

(b) Contact Data

(c) Technical Data

(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 Data

 

(b) Contact Data

(c) Profile Data

(d) Usage Data

(e) Marketing and Communications Data

(f) Technical Data

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 Data

 

(b) Usage Data

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 Data

 

(b) Contact Data

(c) Technical Data

(d) Usage Data

(e) Profile Data

(f) Marketing and Communications Data

Necessary for our legitimate interests (to develop our products/services and grow our business)

Automated decision-making

  1. Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention.
  2. We do not envisage that any serious decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

Marketing

  1. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can opt out of marketing or manage your marketing preferences by logging in to your account.
  2. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
  3. You will receive marketing communications from us if you have requested information from us or purchased products from us and you have not opted out of receiving that marketing.
  4. Sharing your information

We share your personal information with third party contractors and service providers to the extent necessary to fulfil your order.

We share your information with other third parties as follows:

  1. Our regulators, professional advisors, insurance provider and auditors;
  2. HMRC or other government or law enforcement agencies;
  3. If we sell any business or assets, in which case we may disclose your personal information to the prospective buyer of such business or assets;
  4. Payment service providers when you purchase products via the website;
  5. Third parties with which we run joint events and promotional campaigns;
  6. If we have a legal obligation to do so; and
  7. For the purposes of fraud protection and credit risk reduction.

The categories of third parties listed above use your personal data for their own purposes and are responsible for their own compliance with data protection legislation.

  1. We also share your data with third-party service providers who provide services to our business, such as our website host server, IT support and maintenance service, cloud storage provider and email exchange server, delivery services and other businesses that provide certain services on our behalf. All of our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes.
  2. Data security

We have put in place:

  1. Appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
  2. Procedures to deal with any suspected data security breach, and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Transferring information outside the EEA

Any personal information that you submit to us will be held on secure servers, based within the European Economic Area (EEA).

If we are required to transfer your information outside the EEA, we have put in place appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection.

If you are based outside the EEA we may transfer personal information to the correspondence address you provide to us to the extent necessary to complete your order. We will take all reasonable steps to ensure that such transfers are secure. By instructing us from outside the EEA you agree that such transfer is necessary for us to complete your order.

We use Google Analytics to evaluate the performance of our site and improve the service we offer you. We may transfer information about you outside the EEA for this purpose. We will only do so where permitted by law.

[Google Analytics complies with the EU-US Privacy Shield Framework as set out by the US Department of Commerce regarding the collection, use and retention of personal information from European Union member countries. It is subject to enforcement by the Federal Trade Commission. Google, including Google Inc. and its wholly-owned US subsidiaries, has certified that it adheres to the relevant Privacy Shield Principles, including for Google Analytics. For more information about this protective measure, please visit the following: https://www.google.de/intl/en/… long will we keep your personal information for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

We keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for [six] years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see your rights below for further information.

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.

  • Your rights

You have the following rights:

  1. To be told what we are doing with your personal information. We do this by providing you with this privacy notice;
  2. To correct or update the personal information we hold about you.
  3. To object to the processing of your personal information;
  4. To request a copy of the personal information we hold about you;
  5. To ask us to delete the information that we hold about you where there is no good reason for us continuing to process it;
  6. To ask us to stop processing your personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground and where there is no good reason for us continuing to process it;
  7. To ask us to restrict how we use your personal information for a period of time if you claim that it is inaccurate and we want to verify the position or in some limited other circumstances;
  8. To ask us to send your personal information to another organisation in a computer-readable format;
  9. To complain to the Information Commissioner’s office if you are unhappy with our use of your personal data: you can do this at https://ico.org.uk/concerns/. Do contact us straight away if you consider that we are not handling your personal information properly so we can try and sort the problem out.

If we delete your personal information or restrict our use of it, we will not be able to provide our services to you.

If you want to exercise any of your rights, please contact us at the address above. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights).

  • Cookies policy

We make use of cookies on the Website.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. 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 Website.

  1. Essential cookies are necessary for running our websites. For example, they allow you to log in to our website’s secure areas, use a shopping cart or the electronic invoicing service.
  2. Analytical/performance cookies allow us to recognise and count the number of visitors and see how they navigate when using the website. They also help us improve how the website functions, e.g. in order to ensure that all users can easily find what they are looking for.
  3. Functional cookies are used to recognise you when come back to visit our website. They also allow us to personalise the website’s content for you, greet you by name and remember your preferences. These could be, for example, your choice of language and region.
  4. Targeting cookies are used to register your visit on our website, the pages you have visited and the links you clicked on. We use this information to make our website and the advertisements shown on it more relevant to you. We may also share this information with third parties for the same reasons.
  5. Third party cookies. Please note that some third parties may also utilise their own cookies, over which we have lit we have little or no control. You can find out about their use of cookies by visiting the third parties’ websites.

The table below sets out details of the purposes for which we use cookies. You can 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.

Cookie DesignerCookie Name/IDWhat is the cookie expiry date?Cookie Purpose
Google__utma2 years from set/updateUsed to distinguish users and sessions. The cookie is created when the javascript library executes and no existing __utma cookies exists. The cookie is updated every time data is sent to Google Analytics.
Google__utmb30 mins from set/updateUsed to determine new sessions/visits. The cookie is created when the javascript library executes and no existing __utmb cookies exists. The cookie is updated every time data is sent to Google Analytics.
Google__utmcSessionHistorically, this cookie operated in conjunction with the __utmb cookie to determine whether the user was in a new session/visit. This cookies is used to assist operability of the Website.
Google__utmz6 months from set/updateStores the traffic source or campaign that explains how the user reached the Website. The cookie is created when the javascript library executes and is updated every time data is sent to Google Analytics.
Google_ga2 yearsUsed to distinguish users.

If you want to find out more information about cookies, go to http://www.allaboutcookies.org or to find out about removing them from your browser, go to http://www.allaboutcookies.org/manage-cookies/index.html.

  • Third-party links

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 policy of every website you visit.