Maintaining the security of your data is a priority at Sunnylife, and we are committed to respecting your privacy rights. We pledge to handle your data fairly and legally at all times. Sunnylife is also dedicated to being transparent about what data we collect about you and how we use it.
This policy, which applies whether you visit our stores our use our websites and provides you with information about:
- how we use your data;
- what personal data we collect;
- how we ensure your privacy is maintained; and
- your legal rights relating to your personal data.
How we use your data
Sunnylife (and trusted partners acting on our behalf) uses your personal data:
- to provide goods and services to you;
- to make a tailored website & email content available to you;
- to manage any registered account(s) that you hold with us;
- to verify your identity;
- for crime and fraud prevention, detection and related purposes;
- with your agreement, to contact you electronically about promotional offers and products and services which we think may interest you;
- for market research purposes - to better understand your needs;
- to enable Sunnylife to manage customer service interactions with you; and
- where we have a legal right or duty to use or disclose your information (for example in relation to an investigation by a public authority or in a legal dispute).
Sunnylife uses your personal data for electronic marketing purposes (with your consent). Sunnylife aims to update you about products & services which are of interest and relevance to you as an individual. You have the right to opt out of receiving promotional communications at any time, by:
- making use of the simple “unsubscribe” link in emails; or
2. contacting Sunnylife via the contact channels set out in this Policy.
Web Banner Advertising
If you visit our websites, you may receive banner advertisements whilst browsing other websites. Any banner advertisements you see will relate to products you have viewed whilst browsing our websites on your computer or other devices.
Our service providers and suppliers
In order to make certain services available to you, we may need to share your personal data with some of our service partners. These include IT, delivery and marketing service providers.
Sunnylife only allows its service providers to handle your personal data when we have confirmed that they apply appropriate data protection and security controls.
Other third parties
Aside from our service providers, Sunnylife will not disclose your personal data to any third party, except as set out below. We do not sell or rent our customer data to other organisations for marketing purposes.
We may share your data with:
- credit reference agencies where necessary for card payments;
- governmental bodies, regulators, law enforcement agencies, courts/tribunals and insurers where we are required to do so:
- to comply with our legal obligations;
- to exercise our legal rights (for example in court cases);
- for the prevention, detection, investigation of crime or prosecution of offenders; and
- for the protection of our employees and customers.
To deliver products and services to you, it is often necessary for Sunnylife to share your data outside of the European Economic Area. This will typically occur when service providers are located outside the EEA or if you are based outside the EEA. These transfers are subject to special rules under data protection laws.
If this happens, we will ensure that the transfer will be compliant with data protection law and all personal data will be secure. Our standard practice is to use ‘standard data protection clauses’ which have been approved by the European Commission for such transfers. Those clauses can be accessed here.
How long do we keep your data?
We will not retain your data for longer than necessary for the purposes set out in this Policy. Different retention periods apply for different types of data, however the longest we will normally hold any personal data is 3 years.
What personal data do we collect?
Sunnylife may collect the following information about you:
- your name, age/date of birth and gender;
- your contact details: postal address including billing and delivery addresses, telephone numbers (including mobile numbers) and e-mail address;
- purchases and orders made by you;
- your on-line browsing activities on Sunnylife websites;
- your password(s);
- when you make a purchase or place an order with us, your payment card details;
- your communication and marketing preferences;
- your interests, preferences, feedback and survey responses;
- your location;
- your correspondence and communications with Sunnylife; and
- other publicly available personal data, including any which you have shared via a public platform (such as a Twitter feed or public Facebook page).
Our websites are not intended for children and we do not knowingly collect data relating to children.
This list is not exhaustive and, in specific instances, we may need to collect additional data for the purposes set out in this Policy. Some of the above personal data is collected directly, for example when you set up an on-line account on our websites, or send an email to our customer services team. Other personal data is collected indirectly, for example your browsing or shopping activity. We may also collect personal data from third parties who have your consent to pass your details to us, or from publicly available sources.
Sunnylife is committed to keeping your personal data safe and secure.
Our security measures include:
- encryption of data;
- where possible, the deidentification of data;
- regular cyber security assessments of all service providers who may handle your personal data;
- security controls which protect the entire Sunnylife IT infrastructure from external attack and unauthorised access; and
- internal policies setting out our data security approach and training for employees.
You have the following rights:
- the right to ask for a copy of personal data that we hold about you (the right of access);
- the right (in certain circumstances) to request that we delete personal data held on you; where we no longer have any legal reason to retain it (the right of erasure or to be forgotten);
- the right to ask us to update and correct any out-of-date or incorrect personal data that we hold about you (the right of rectification);
- the right to opt out of any marketing communications that we may send you and to object to us using / holding your personal data if we have no legitimate reasons to do so (the right to object);
- the right (in certain circumstances) to ask us to ‘restrict processing of data’; which means that we would need to secure and retain the data for your benefit but not otherwise use it (the right to restrict processing); and
- the right (in certain circumstances) to ask us to supply you with some of the personal data we hold about you in a structured machine-readable format and/or to provide a copy of the data in such a format to another organisation (the right to data portability).
If you wish to exercise any of the above rights, please contact us by emailing firstname.lastname@example.org.
Legal basis for Sunnylife processing customer personal data
Sunnylife collects and uses customers’ personal data because is it necessary for:
- the pursuit of our legitimate interests (as set out below);
- the purposes of complying with our duties and exercising our rights under a contract for the sale of goods to a customer; or
- complying with our legal obligations.
In general, we only rely on consent as a legal basis for processing personal data in relation to sending direct marketing communications to customers via email or text message.
Customers have the right to withdraw consent at any time. Where consent is the only legal basis for processing, we will cease to process data after consent is withdrawn.
Our legitimate interests
The normal legal basis for processing customer data, is that it is necessary for the legitimate interests of Sunnylife, including:
- selling and supplying goods and services to our customers;
- protecting customers, employees and other individuals and maintaining their safety, health and welfare;
- promoting, marketing and advertising our products and services;
- understanding our customers’ behaviour, activities, preferences, and needs;
- improving existing products and services and developing new products and services;
- complying with our legal and regulatory obligations;
- preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies;
- handling customer contacts, queries, complaints or disputes;
- managing insurance claims by customers;
- protecting Sunnylife, its employees and customers, by taking appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to Sunnylife;
- effectively handling any legal claims or regulatory enforcement actions taken against Sunnylife; and
- fulfilling our duties to our customers, colleagues, shareholders and other stakeholders.
What are cookies?
How are cookies managed?
The cookies stored on your computer or other device when you access our websites are designed by:
- Sunnylife, or on behalf of Sunnylife;
- third parties who participate with us in marketing programmes; and
- third parties who broadcast web banner advertisements on behalf of Sunnylife.
What are cookies used for?
The main purposes for which cookies are used are: -
- For technical purposes essential to effective operation of our websites, particularly in relation to on-line transactions and site navigation.
2. For Sunnylife to market to you, particularly web banner advertisements and targeted updates.
3. To enable Sunnylife to collect information about your browsing and shopping patterns, including to monitor the success of campaigns, competitions etc.
4. To enable Sunnylife meet its contractual obligations to make payments to third parties when a product is purchased by someone who has visited our website from a site operated by those parties.
How do I disable cookies?
If you want to disable cookies you need to change your website browser settings to reject cookies. How you can do this will depend on the browser you use. Further information on disabling cookies can be found on the website of the browser you use.
What happens if I disable cookies?
This depends on which cookies you disable, but in general the website may not operate properly if cookies are switched off. If you only disable third party cookies, you will not be prevented from making purchases on our sites. If you disable all cookies, you may be unable to complete a purchase on our sites.
Data Protection Officer
Sunnylife has appointed a Data Protection Officer to ensure we protect the personal data of our customers (and others) and comply with data protection legislation.
If you have any questions about how Sunnylife uses your personal data that are not answered here, or if you want to exercise your rights regarding your personal data, please contact our Data Protection Officer by emailing email@example.com.
You have the right to lodge a complaint with the Information Commissioner’s Office. Further information, including contact details, is available at https://ico.org.uk.
This policy was last updated in May 2018.