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Marleybones privacy policy

How we approach privacy

Marleybones Limited known as Marleybones operates a service that allows you to tailor, select and order dog food for your dog using our website at https://marleybones.com.

We take the privacy of your information very seriously and is committed to protecting and respecting your privacy. This privacy notice will inform you as to how we process your personal data on our website and when you subscribe and register as a user of our services. This privacy notice also tells you about your privacy rights pursuant to the Data Protection Act 2018 and UK GDPR (“Data Protection Laws”).

This privacy notice should be read alongside and in addition to our Terms and Conditions which can be found at: www.marleybones.com/terms-and-conditions.

Controller for personal data

A “controller” is a person or organisation who alone or jointly determines the purposes for which and the way any personal data is or is likely to be processed. Unless we notify you otherwise Marleybones is the controller of your personal data.

Scope

This privacy notice applies to the processing of personal data by us in connection with any:

  • Organisations or persons for the provision of services by us.
  • Visitors on our website.

Types of personal data

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. This is known as anonymised data. Anonymised data falls outside the scope of Data Protection Laws.

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

  • Identity Data includes first name, last name, username or similar identifier and title.
  • 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 for the provision of 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 our website.
  • Profile Data includes your username and password, searches made by you, your ratings and comments, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. 

How we collect your personal data

Directly from you: You give us your personal data in your direct interactions with us. Such personal data includes Identity Data, Contact Data, Financial Data, Profile Data, Usage Data, Technical Data, Marketing and Communications Data (i) by filling in forms on our website (ii) by leaving ratings and comments (iii) by corresponding with us by email or post (iv) by calling us over the telephone.

This includes personal data you provide when you:

  1. When you contact us through the website, by telephone, post, e-mail or through any other means.
  2. When you register with us and set up an account to receive our products/services.
  3. When you complete surveys that we use for research purposes (although you are not obliged to respond to them).
  4. When you enter a competition or promotion through a social media channel.
  5. When you make payments to us, through this website or otherwise.
  6. When you elect to receive marketing communications from us.
  7. When you use our services.

From use of our website

We automatically collect some information about your visit to the website. We gather information and statistics collectively about visitors to our website. Analysis of this information demonstrates the most frequently used sections of the website and assists us in continually improving the online service. You give us your personal data, which includes Profile Data, Usage Data, Technical Data and/or Marketing and Communications Data when you use our website or which we have agreed with you to use or when you review any publications or marketing material we send you.

This information helps us to make improvements to website content and navigation, and includes your IP address, the date, times and frequency with which you access the website and the way you use and interact with its content. We will collect information automatically via cookies in line with the cookie settings on your browser. For more information about cookies, and how we use them on the website please see our cookies notice for more information.

Indirectly: Third-party sources: We receive Identity Data, Contact Data, Usage data about you from third parties when:

  • we provide our services or other parties send us your personal data to enable the provision of those service.
  • you provide your personal data to a third party for the purpose of sharing it with us.

Providing personal data

Where we need to collect personal data by law or under the terms of a contract we have with you and you do not provide that information 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 our services. In this case we may have to cancel our service but we will notify you if this is the case at the time.

How we use your personal data

We will only use your personal data when the law allows us to. We will use your personal data in the following circumstances:

  • Performance of a contract: Where we need to perform the contract we are about to enter into or have entered into with you. For example when you sign up to our services.
  • Legal obligation: Where we need to comply with a legal obligation. For example for accounting or legal purposes.
  • Legitimate interests: Where it is necessary for our legitimate interests or those of a third party and your interests and fundamental rights do not override those interests.
  • Consent: We do not generally rely on consent as a legal basis for processing your personal data. Where we do rely on consent you have the right to withdraw consent at any time. Please contact us at hello@marleybones.com to withdraw consent. Please also see Marketing communications.

Purposes for which we will use your personal data

We have set out below in a table format a description of all the ways we plan to use your personal data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

 

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you for the provision of our services. (a) Identity

(b) Contact

Performance of a contract with you
To respond to any enquires (a) Identity

(b) Contact

(a) Performance of a contract with you

(b) Necessary for our legitimate interests

To process and deliver our services to you including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests i.e., 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 notice

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests i.e., to keep our records updated and to study how customers use our products/services

To administer and protect our business and this website including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data (a) Identity

(b) Contact

(c) Technical

(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

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests i.e., 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

(b) Usage

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

 

Note: Where applicable consent will be used for data analytics obtained through cookies or similar technologies. See our cookies notice

To make suggestions and recommendations to you about our services that may be of interest to you (a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

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

 

Marketing communications

For the delivery of direct marketing to you via e-mail or SMS we’ll need your consent whether via an opt-in or soft-opt-in:

(a) soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under “soft opt-in” consent, we will take your consent as given unless you opt-out.
(b) for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we’ll provide.

You have the right to object to processing of your personal data for direct marketing purposes. You can unsubscribe from receiving marketing communications from us by using the unsubscribe methods contained in communications we send to you or by contacting us. See Contact us. Where you opt out of receiving marketing communications this will not apply to personal data provided to us as a result of registering for or using our service, your service experience or other interactions with this website.

How we share your personal data

We may have to share your personal data with the parties set out below:

  • Internally: Your personal data will be used by our employees and contractors who are working on providing your services to you on a need-to-know basis.
  • Suppliers: This would include service providers who support our business including IT and communication suppliers and outsourced business support to ensure our service runs smoothly.
  • Professional advisers: This would include lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • Law enforcement bodies, regulators and other authorities: This is to comply with our legal requirements or adhere to good practices.
  • Advertising networks and analytics service providers: This is to support and display ads on our website, apps and other social media tools.
  • Social media platform providers: To support our marketing communications such as Instagram, Snapchat and TikTok.
  • Third parties: This is in the context of the acquisition or transfer of any part of our business or in connection with the business reorganisation. If a change happens to our business then the new owners may use your personal data in the same way as set out in this privacy notice.

Some information about our suppliers for our services.

Stripe We use Stripe for online payments processing. The cookies are used for temporary tracking and analytics data.

 

Privacy Policy: https://stripe.com/gb/privacy

 

Google During the sign-up process we make use of the Google Maps API to allow us to locate a user by their postcode. No cookies are currently set by Google, but this may change in the future.

 

Privacy Policy: https://policies.google.com/privacy
Google Analytics Google Analytics is a web analytics suite by Google Inc. It uses cookies to collect information about how our visitors use our site. This information is used to compile usage reports, such as what page Privacy Policy: https://marketingplatform.google.com/about/analytics/terms/us/
Vimeo We use YouTube to display video content on our site. To do this, Vimeo sets various cookies to assist with user preferences and playback settings. Privacy Policy:

https://vimeo.com/privacy

 

TrustPilot We use TrustPilot as a tool to review our services. Privacy Policy: https://uk.legal.trustpilot.com/end-user-privacy-terms
Mailchimp We use Mailchimp for updating purposes such as order confirmations, newsletters and surveys. Privacy Policy: https://mailchimp.com/legal/privacy/
Klaviyo

 

We use Klaviyo for updating purposes such as order confirmations, newsletters and surveys. Privacy Policy:

https://www.klaviyo.com/legal/privacy

 

Evri We use Evri as a courier for the purposes of shipping your order to you. Privacy Policy:

https://www.evri.com/privacy-policy 

Facebook To show you targeted adverts through your Facebook account in accordance with your advertising and tracking preferences. Privacy policy:

https://www.facebook.com/privacy/policy/

 

Clarity/

Microsoft

We use Clarity to gain understanding of how you use our website. Privacy policy:

https://privacy.microsoft.com/en-us/privacystatement

 

Weld We use Weld for our data management use. Privacy policy:

https://weld.app/privacy-policy

 

Sleeknote We use Sleeknote for marketing administration. Privacy policy:

https://sleeknote.com/privacy-policy

Kinsta We use Kinsta as a hosting provider. Privacy policy:

https://kinsta.com/legal/privacy-policy/

 

 

International transfers

How we safeguard personal data when we transfer it internationally

We ensure a similar degree of protection is afforded whenever we transfer personal data out of the UK by ensuring at least one of the following safeguards is implemented:

  1. We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information; or
  2. We will use specific contracts approved for use in the UK which give personal information the same protection it has in the UK. For example, the use of Article 46 UK/EU GDPR safeguard mechanisms to transfer personal data.

Please contact us if you would like further information on our international transfers.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

The transmission of information via the internet is not completely secure. Although we will take reasonable measures to protect your personal data, we cannot guarantee the security of your information transmitted and any transmission is at your own risk.

Examples of our security measures

  • access to your account is controlled by a password and a username that is unique to you.
  • we store information on secure servers.
  • payment details are encrypted using SSL technology. Typically you will see a lock icon or green address bar (or both) in your browser when we use this technology.

Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your information, please let us know immediately by contacting us via this e-mail address: hello@marleybones.com

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org  Get Safe Online is supported by HM Government and leading businesses.

Data retention

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 information we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means and the applicable legal, regulatory, tax, accounting or other requirements.

We may 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.

Data Subject Rights

Under certain circumstances, you have rights under Data Protection Laws. You can:

Request access to your personal data: This is known as a “data subject access request” and enables you to receive a copy of the personal data Marleybones hold about you.

Request correction of your personal data: This enables you to have any incomplete or inaccurate information we hold about you corrected.

Request erasure of your personal data: This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Note: We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you at the time of your request.

Object to processing of your personal data: This is where we are processing your personal data based on a legitimate interest or those of a third party and you may challenge this.  However, we may be entitled to continue processing your information based on our legitimate interests or where this is relevant to any legal claims.  See also Marketing communications.

Request restriction of processing your personal information: This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the information’s accuracy (b) where our use of the information is unlawful but you do not want us to erase it (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.

Request transfer of your personal information (“data portability”):  This is where in some circumstances we will provide to you or a third party you have chosen your personal data in a structured, commonly used, machine-readable format.

Right to withdraw consent: This is where we are relying on consent to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. Depending on the processing activity, if you withdraw your consent we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

Automated decision making:  This is where decisions are made about you by automated means. We do not carry out automated decision making.

Keeping personal information accurate and current

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. If you wish to update your personal data please contact us. See Contact us.

Carrying out your data subject rights

You will not have to pay a fee to access your personal data or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information or to exercise any of your other rights. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If you wish to exercise any of the rights set out above, please contact us at  hello@marleybones.com

Concerns and complaints

We would appreciate the chance to deal with your concerns in the first instance. Please see Contact us section. If you have unresolved concerns and you live or work in the UK or believe that a personal data breach happened in the UK you have the right to complain at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).

If you live or work outside the UK or you have a complaint concerning our personal data processing activities you may lodge a complaint with another supervisory authority.

Links to other websites

This website may from time to time provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy notice does not extend to your use of such websites. You are advised to read the privacy notice or statement of other websites prior to using them.

Changes to our privacy notice

This privacy notice may be changed from time to time in response to legal, technical or business developments. We will take appropriate measures to inform you when we update our privacy notice. We will obtain your consent to any material privacy notice changes if and where this is required by applicable Data Protection Laws.

Contact us 

If you would like more information about the way, we manage personal information that we hold about you please contact us at:

Email address: hello@marleybones.com

This version was last updated on 16 September 2022.