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This webpage sets out when and how we use your personal information that you or others provide to us.

 

WHO WE ARE

We are M&M Cosmetics Ltd (trading as “Sofnfree Naturals”). A limited company registered in Ireland at the Registrar of Companies in Dublin, Ireland, under company registration number 81843, with its UK branch office at Unit 13 Watford Metro Centre, Dwight Road, Watford, WD18 9SB, United Kingdom, (“M&M Cosmetics Ltd”, “we”, “us” or “our”).  The Company’s registered office address in Ireland is 1st Floor, 9 Exchange Place, IFSC, Dublin 1, Republic of Ireland.

 

HOW DO YOU USE MY DATA?

Your personal data is processed to:

  1. deliver marketing content, if you have expressed interest in our products and consented to it,
  2. provide functionality of out website and facilitate the use of our services (details on the use of cookies at the end of this policy)
  3. implementation and performance of contracts with customers or contractors,
  4. implementation of obligations resulting from law, including billing, accounting, and financial reporting,
  5. in controller’s legitimate interests, namely contact purposes,

We also process personal data in connection with the implementation of our other legitimate interests:

  1. for the establishment, exercise or defence of legal claims,
  2. for statistical purposes related to the improvement of work efficiency, quality of provided services and adapting them to recipients.

 

WHEN YOU PURCHASE PRODUCTS FROM OUR WEBSITE

When you purchase goods from our website, we will use your personal information to complete your purchase. The details we collect from you will include your name, address, payment and other contact details.

To complete your purchase, we share your personal information with our subcontractors who are involved in the purchase process, such as payment providers, as well as credit reference agencies who we use to assess fraud, credit and/or security risks.

We need to process your personal information in this way to enter into and perform the contract for the item you have purchased from us.

 

WHEN YOU PURCHASE PRODUCTS IN STORE

As with an online purchase, when you purchase goods from us in store, we will use your personal information to complete your purchase. The details we collect from you will include your name, address, payment and other contact details.

To complete your purchase, we share your personal information with our subcontractors who are involved in the purchase process, such as payment providers, as well as credit reference agencies who we use to assess fraud, credit and/or security risks.

We need to process your personal information in this way to enter into and perform the contract for the item you have purchased from us.

 

WHEN YOU PHONE US

When you phone us, we may also handle your personal information (your name, contact details and the other details you provide to us) in order to provide the customer services, you have asked us to. This could be when you ask us to confirm whether a particular product is available or explain how our delivery or returns process works.

 

We rely on your consent to handle your personal information in this way. If you do not provide us with the personal information we request from you for customer services purposes, we may not be able to fully answer your queries.

 

WHEN YOU HAVE EXPRESSED AN INTEREST IN OUR PRODUCTS

If you have opted in via our website or over the telephone to receive marketing communications from us, we will handle your personal information (such as your name, email address and postal address and telephone number) to provide you with marketing communications in line with any preferences you have told us about.

When we send you marketing emails, we rely on your consent to contact you for marketing purposes. Every email we send to you for marketing purposes will also contain instructions on how to unsubscribe from receiving them.

When we send you marketing material in the post, we rely on our legitimate interest to let you know about our latest special offers.

You are not under any obligation to provide us with your personal data for marketing purposes.

You can tell us that you do not want your personal information to be processed in this way at any time by contacting us at info@sofnfreenaturals.com or, where relevant, by following the unsubscribe link shown in every marketing communication you receive from us.

 

TO MAKE OUR SITE BETTER

We will also use your personal information to provide you with a more effective user experience (such as by displaying products we think you will be interested in, based on your purchase history and browsing habits).

Our use of your information in this way means that your experience of our site will be more tailored to you, and that the products you see on our site may differ from someone accessing the same site with a different purchase history or browsing habits.

We also share your aggregated, anonymous data with third party analytics and search engine providers that assist us in the improvement and optimisation of our site.

We will also use your personal information for the purposes of making our site more secure, and to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.

We process your data for this reason because we have a legitimate interest to provide you with the best experience we can, and to ensure that our site is kept secure.

You can prevent us from using your personal information in this way by using the ‘do not track’ functionality in your internet browser. If you enable do not track functionality, our site may be less tailored to your needs and preferences.

 

IF OUR BUSINESS IS SOLD

We will transfer your personal information to a third party:

If we sell or buy any business or assets, we will provide your personal information to the seller or buyer (but only to the extent we need to, and always in accordance with data protection legislation); or

If Sofnfree Naturals or the majority of its assets are acquired by somebody else, in which case the personal information held by Sofnfree Naturals will be transferred to the buyer.

We process your personal information for this purpose because we have a legitimate interest to ensure our business can be continued by the buyer. If you object to our use of your personal information in this way, the relevant seller or buyer of our business may not be able to provide services to you.

In some circumstances we may also need to share your personal information if we are under a duty to disclose or share it to comply with a legal obligation.

 

WHAT ABOUT TECHNICAL INFORMATION AND ANALYTICS?

Information we collect about you: When you visit our site, we will automatically collect the following information:

Technical information, including the Internet protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, screen resolution, operating system and platform; and

Information about your visit, including the full Uniform Resource Locators, clickstream to, through and from our site (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.

Information we receive from other sources: We are also working closely with third party advertising networks, analytics providers, hosting providers and search information providers from whom we may also receive general aggregated anonymous information about you.

We will combine the information you provide to us with information we collect about you.

 

COOKIES

We use necessary cookies to make our site work. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. We only use (and store) non-essential cookies on your computer’s browser or hard drive if you provide your consent.

We'd also like to set other optional cookies to help us improve it. We won't set optional cookies unless you enable them, using the tool provided to your attention when you first open the website. Using this tool will set a cookie on your device to remember your preferences.

Before deciding to completely block any cookies, please be aware that necessary cookies enable core functionality such as security, network management, and accessibility. You may disable these by changing your browser settings, but this may affect how the website functions. Instructions on how to change web browser settings for most common browsers are available at:

 

 

SHOPIFY

Purpose: Shopify uses cookies, or tiny pieces of information stored on your computer, to verify who you are. There are cookies for logged in users and for commenters.

More information: https://www.shopify.co.uk/legal/cookies

 

GOOGLE ANALYTICS

Purpose: Google Analytics is a simple, easy-to-use tool that helps website owners measure how users interact with website content. As a user navigates between web pages, Google Analytics provides website owners JavaScript tags (libraries) to record information about the page a user has seen, for example the URL of the page. The Google Analytics JavaScript libraries use HTTP Cookies to “remember” what a user has done on previous pages / interactions with the website.

Google Analytics supports two JavaScript libraries (tags) for measuring website usage: analytics.js and ga.js. The following sections describe how each use cookies.

More information: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage

 

WEB BROWSER COOKIES (FIRST PARTY COOKIES OR STRICTLY NECESSARY COOKIES)

Purpose: These Cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas. Without these Cookies services you have asked for e.g. shopping baskets or e-billing, cannot be provided. We also use Cookies to help us to improve the performance of our website to provide you with a better user experience.

 

THIRD PARTY COOKIES

Purpose: Third Party Cookies are set by a different organisation to the owner of the website you are visiting. For example, the website might use a third-party analytics company who will set their own Cookie to perform this service. The website you are visiting may also contain content embedded from, for example YouTube or Flickr, and these sites may set their own Cookies.

More significantly, a website might use a third-party advertising network to deliver targeted advertising on their website. These may also have the capability to track your browsing across different sites.

Third Party Cookies will only be used by Knotel to analyse usage rates and error management of the site and as such will help us to improve the performance of the website. They will NOT be used:

 

to gather information that could be used for marketing to the user; or

to remember user preferences or ID’s outside a single session.

 

SESSION COOKIES

Purpose: Session Cookies are stored only temporarily during a browsing session and are deleted from the user’s device when the browser is closed.

Once you have closed down your browser the Cookie is automatically deleted.

 

PERSISTENT COOKIES (FUNCTIONALITY COOKIES)

Purpose: These Cookies are saved on your computer for a fixed period (usually a year or longer) and is not deleted when the browser is closed. Persistent Cookies are used where you might need to be known in the likelihood that you will return for further browsing sessions. For example, a web site such a s the BBC use this type of Cookie to store your preferences, so that they are remembered for the next visit – if you set your location on the BBC homepage in order to receive your local news and weather forecast, Cookies are used to save your location preference.

Functionality Cookies may also take the form of Flash Cookies, which are stored in your Adobe Flash Player rather than your browser. These are used to provide features such as auto-resume on iPlayer, by remembering the point to which you played a programme, and for saving preferences such as your volume setting.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, which we do not have any control over. These cookies are likely to be analytical/performance cookies or targeting cookies.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies (instructions on how to change web browser settings placed above). We kindly remind that 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.

Except for essential cookies, all cookies will expire after 2 years.

 

WHERE IS MY DATA STORED?

All information you provide to us is stored on secure servers.

In principle, your personal data will be processed in the United Kingdom. Taking into account the services provided by the controller's subcontractors in the implementation of support for ICT services, IT infrastructure or marketing tools, the controller may commission specific activities or tasks to recognized subcontractors operating outside the UK and of the European Economic Area (EEA) Member States, which may result in the transfer of your data outside these States.

 

Recipient states from outside the EEA, covered by the European Commission’s decision, ensure an adequate level of personal data protection in accordance with EEA standards. In the case of recipients in the territory of countries not covered by the decision of the European Commission, in order to ensure an adequate level of data protection, the controller concludes contracts with the recipients of your personal data, based on standard contractual clauses issued by the European Commission in accordance with art. 46(2)(c) of the GDPR.

 

A copy of the standard contractual clauses can be obtained from the controller by contacting the contact details provided above. The method of securing your data used by the Controller complies with the principles provided for in Chapter V of the GDPR. You can request further information about the security measures applied in this regard, obtain a copy of these security features and information on where they are made available.

HOW LONG DO WE RETAIN YOUR DATA FOR?

Where you have purchased goods from us, we will retain your data for a period of 7 years for legal purposes, to ensure that we are able to assist you should you have any questions, feedback or issues in connection with a product you have purchased from us or if any legal issues arise – For example a VAT issue.

 

Where we have used your personal information to contact you for marketing communications:

 

We will contact you at least every 3 years to ensure you are happy to continue receiving electronic communications; or

Every 5 years to ensure you are happy to continue receiving postal and telephone communications from us.

If you tell us that you no longer wish to receive marketing communications from us, we promise to stop sending them to you.

 

Where we have processed your data for any other reason (such as where you have contacted us with a question in connection with potentially purchasing a product) we will retain your data for 3 yearsor for the period required to fulfill the purposes for which the data was collected, whichever is longer.

 

YOUR RIGHT TO OBJECT UNDER DATA PROTECTION LAWS

You have the right to object to us handling your personal information when:

 

We are handling your personal information based on our legitimate interests (as described in the “How do you use my data” section above). If you ask us to stop handling your personal information in this way, we will stop unless we can show you that we have compelling grounds as to why our use of your personal information should continue; or

For marketing purposes. If you ask us to stop handling your personal information on this basis, we will stop.

 

WHAT ARE MY RIGHTS UNDER DATA PROTECTION LAWS?

You have various rights under the data protection laws, which you can exercise by contacting us. The easiest way to do this is by email at info@sofnfreenaturals.com

 

RIGHT OF ACCESS

You are entitled to receive confirmation as to whether your personal information is being processed by us, as well as various other information relating to our use of your personal information.

 

You also have the right to access your personal information which we are handling.

 

RIGHT TO RECTIFICATION

You have the right to require us to rectify any inaccurate personal information we hold about you. You also have the right to have incomplete personal information we hold about you completed, by providing a supplementary statement to us.

 

RIGHT TO RESTRICTION

You can restrict our processing of your personal information where:

 

You think we hold inaccurate personal information about you;

Our handling of your personal information breaks the law, but you do not want us to delete it;

We no longer need to process your personal information, but you want us to keep it for legal reasons; or

Where you exercise your right to restrict us from using your personal information, we will then only process your personal information when you agree, except for storage purposes and to handle legal claims,unless there are overriding grounds on our part for processing this data.

 

RIGHT TO DATA PORTABILITY

You have the right to receive the personal information we hold about you in a structured, standard machine-readable format and to send this to another organisation controlling your personal information.

 

RIGHT TO ERASURE

You have the right to require us to erase your personal information which we are handling in the following circumstances:

 

Where we no longer need to use your personal information for the reasons we told you we collected it for;

Where we needed your consent to use your personal information and you have withdrawn your consent;

When you object to our use of your personal information and we have no compelling reason to carry on handling your personal information;

if our handling of your personal information has broken the law;

when we must erase your personal information to comply with a law we are subject to.

 

RIGHT TO COMPLAIN

You have the right to lodge a complaint with the Information Commissioner’s Office, the supervisory authority for data protection issues in England and Wales.

 

WHAT ABOUT WEBSITES WE LINK TO?

Our site may, from time to time, contain links to and from the websites of our partner networks and affiliates.

Our site connects you to different websites.  If you follow a link to any of these websites or use our services, please note that you have left our site and these websites have their own privacy policies.

We do not accept any responsibility or liability for these policies or websites.  Please check their policies before you submit any personal information to these websites.

 

WHEN WILL YOU CHANGE YOUR PRIVACY POLICY?

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail or post.

 

Please check back frequently to see any updates or changes to our privacy policy.

 

HOW DO I CONTACT YOU WITH FEEDBACK?

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to info@sofnfreenaturals.com

 

This privacy policy was last updated on 29th March 2023.