I

Privacy Notice

This is the privacy notice of Cuddle Me Up Slings Limited, company number 12213751 ("we", "our", or "us").

Our registered office is at 71-75 Shelton Street, London, WC2H 9JQ.

Introduction

This privacy notice aims to inform you about how we process information that we collect from you or that you provide to us. It covers information that could identify you as an individual (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.

It applies to information collected in our stores, on our website or through social media platforms, including Facebook and Instagram.

This policy complies with the Data Protection Act 2018 (Act) accordingly incorporating the EU General Data Protection Regulation (GDPR).

The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal information. We do this now, by requesting that you read the website at http://www.knowyourprivacyrights.org 

We are committed to protecting your privacy and the confidentiality of your personal information. Our policy is not just an exercise in complying with the law, but a continuation of our respect for you and your personal information.

We undertake to preserve the confidentiality of all information you provide to us and hope that you reciprocate.

Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.

  1. Data Protection Officer

We have appointed a Data Protection Officer (DPO) who is responsible for ensuring that our policy is followed.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our DPO, Rebecca Barton at cuddlemeupslings@hotmail.com.

2.Types of information we process

We may collect, use, store and transfer different kinds of personal information about you. These can be grouped as follows:

“Identity Information” includes information such as your first name, your last name, your title, your date of birth, and other identifiers that you may have provided at some time.

“Contact Information” includes information such as your billing address, your delivery address, your email address, telephone numbers and any other information you have given to us for the purpose of communication or meeting.

“Financial Information” includes information such as your bank account and payment card details.

“Transaction Information” includes details about payments or communications to and from you and information about products and services you have purchased from us.

“Technical Information” includes your Internet protocol (IP) address, 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 Information” includes information such as your username and password, and your interests, preferences, feedback and survey responses.

“Marketing Information” includes your preferences in receiving marketing from us; communication preferences; responses and actions in relation to your use of our services.

We may aggregate anonymous data such as statistical or demographic data for any purpose. Anonymous data is data that does not identify you as an individual. Aggregated data may be derived from your personal data but is not considered personal information in law because it does not reveal your identity.

For example, we may aggregate Technical Information to assess interest in a product or service.

However, if we combine or connect aggregated data with your personal information so that it can identify you in any way, we treat the combined data as personal information and it will be used in accordance with this privacy notice.

3.Special category data

Special category data is defined by the law as information about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions and trade union membership. It also includes health, genetic and biometric data.

We may process special category data about you if there is a need and a lawful basis to do so. This may include information about your or your child’s health for the purpose of providing safe and correct fitting advice pertaining to slings and carriers.

4.If you do not provide personal information we need

Where we need to collect personal information by law, or under the terms of a contract we have with you, and you fail to provide that information when requested, we may not be able to perform that contract. In that case, we may have to stop providing a service to you. If so, we will notify you of this at the time.

The bases on which we process information about you

The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.

If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.

If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

5.Information processed under a contract

When you create an account on our website, buy a product, or book one of our services, you enter into a contract with us or express intention to do so.

We process the information you give us on the basis there is a contract between us, or that you have requested we use the information before we do so.

Some of this information may be personal information such as Identity Information, Contact Information, Financial Information and Transaction Information.

We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

6.Information we process with your consent

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including our products and services, you provide your consent to us to process information that may be personal information.

For example, you may provide us with Identity Information and Contact Information so that we can reply to a message.

If you have given us explicit permission to do so, we may from time to time pass your name and Contact information to selected associates whom we consider may provide services or products you would find useful.

We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by telling us. However, if you do so, you may not be able to use our website or our services further.

7.Information we process for the purposes of legitimate interests

We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.

Where we process your information on this basis, we do after having given careful consideration to:

● whether the same objective could be achieved through other means

● whether processing (or not processing) might cause you harm

● whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so

For example, we may process your data on this basis for the purposes of:

● record-keeping for the proper and necessary administration of our business

● responding to unsolicited communication from you to which we believe you would expect a response

● protecting and asserting the legal rights of any party

● insuring against or obtaining professional advice that is required to manage business risk

● protecting your interests where we believe we have a duty to do so

8.Information we process because we have a legal obligation

Sometimes, we must process your information in order to comply with a statutory obligation.

For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

This may include your personal information.

Specific uses of personal information you provide

9.Information you provide under the expectation that it will be shared with others

Our website may allow you to post information with a view to it being read, copied, downloaded, or used by other people.

Examples include: posting a review, tagging an image and clicking on an icon next to another visitor’s message to convey your agreement, disagreement or thanks.

In posting personal information, it is up to you to satisfy yourself about the sensitivity of the information and the privacy level of every person who might use it.

We do not specifically use this information except to allow it to be displayed or shared.

We do store it, and we reserve a right to use it in the future in any way we decide.

Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.

Provided your request is reasonable and there is no legal basis for us to retain it, then at our discretion we may agree to your request to delete personal information that you have posted. You can make a request by contacting us.

10.Information relating to your method of payment

Payment information is never taken by us or transferred to us either through our website or otherwise. Our employees and contractors never have access to it.

At the point of payment, you are transferred to a secure page on the website of a reputable payment service provider. We use the services of SumUp, PayPal and Wix Payments. The payment page may be branded to look like a page on our website, but it is not controlled by us.

11.Information about a direct debit

When you agree to set up a direct debit arrangement, the information you give to us is passed to our own bank, NatWest, for processing according to our instructions. We do not keep a copy.

We keep this information only for the duration of the direct debit arrangement. 

We are registered under the direct debit guarantee scheme. This provides for the customer's bank to refund disputed payments without question, pending further investigation.

Direct debits can only be set up for payments to beneficiaries that are approved originators of direct debits. In order to be approved, these beneficiaries are subjected to careful vetting procedures. Once approved, they are required to give indemnity guarantees through their banks.

12.Job application and employment

If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you at a later date.

If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.

13.Affiliate and business partner information

This is information given to us by you in your capacity as an affiliate of us or as a business partner.

It allows us to recognise visitors that you have referred to us, and to credit to you commission due for such referrals. It also includes information that allows us to transfer commission to you.

The information is not used for any other purpose.

We undertake to preserve the confidentiality of the information and of the terms of our relationship.

We expect any affiliate or partner to agree to reciprocate this policy.

Use of information we collect through automated systems when you visit our website

14.Cookies

Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit a website that uses them. They allow information gathered on one web page to be stored until it is needed for use at a later date.

They are commonly used to provide you with a personalised experience while you browse a website, for example, allowing your preferences to be remembered.

They can also provide core functionality such as security, network management, and accessibility; record how you interact with the website so that the owner can understand how to improve the experience of other visitors; and serve you advertisements that are relevant to your browsing history.

Some cookies may last for a defined period of time, such as one visit (known as a session), one day or until you close your browser. Others last indefinitely until you delete them.

Your web browser should allow you to delete any cookie you choose. It also should allow you to prevent or limit their use. Your web browser may support a plug-in or add-on that helps you manage which cookies you wish to allow to operate. 

The law requires you to give explicit consent for use of any cookies that are not strictly necessary for the operation of a website.

We use cookies in the following ways:

  • to track how you use our website

  • to record whether you have seen specific messages we display on our website

  • to keep you signed in to our website

  • to record and remember choices you make while browsing our website.

  • to record your answers to surveys and questionnaires on our website while you complete them

  • to record the conversation thread during a live chat with our support team

This website is hosted by Wix, which uses cookies for a number of different reasons including for security purposes; for monitoring the performance of this website; and for providing a good experience for visitors. You can read more about how Wix uses cookies at https://support.wix.com/en/article/cookies-and-your-wix-site

15.Personal identifiers from your browsing activity

Requests by your web browser to our servers for web pages and other content on our website are recorded.

We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.

We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.

If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.

16.Our use of advertising and re-marketing services

Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advert for our products or services when you visit some other website.

We may use a third party such as Google, Microsoft or Facebook to provide us with marketing services from time to time. If so, then if you have consented to our use of cookies, you may see advertisements for our products and services on other websites.

Facebook’s privacy policy can be found at https://en-gb.facebook.com/business/m/privacy-and-data

Google’s privacy policy can be found at https://policies.google.com/technologies/ads?hl=en-GB

Microsoft’s privacy policy can be found at https://about.ads.microsoft.com/en-gb/resources/policies/privacy-and-data-protection-policies 

Disclosure and sharing of your information

17.Third party advertising on our website

Third parties may advertise on our website. In doing so, those parties, their agents or other companies working for them may use technology that automatically collects information about you when their advertisement is displayed on our website.

They may also use other technology such as cookies or JavaScript to personalise the content of, and to measure the performance of their adverts.

We do not have control over these technologies or the data that these parties obtain. Accordingly, this privacy notice does not cover the information practices of these third parties.

18.Credit reference

To assist in combating fraud, we share information with credit reference agencies, so far as it relates to clients or customers who instruct their credit card issuer to cancel payment to us without having first provided an acceptable reason to us and given us the opportunity to refund their money.

Other matters

19.Data may be processed outside the European Union

Our business is based in the UK.

The global headquarters of our website hosting provider Wix are in Israel. Israel is considered by the European Commission to offer an adequate level of protection for the personal information of EU Member State residents.

Your personal information may be stored through Wix’s data storage, databases and the general Wix applications. Data is stored on secure servers behind a firewall.

Your data may be maintained, processed and stored by Wix and their authorised affiliates and service providers in the United States of America, in Europe (including in Lithuania, Germany and Ukraine), in Israel, and in other jurisdictions as necessary for the proper delivery of their services and/or as may be required by law.

Wix affiliates and service providers that store or process your data on Wix’s behalf are each contractually committed to keep it protected and secured, in accordance with industry standards and regardless of any lesser legal requirements which may apply in their legal jurisdiction.

Wix’s full privacy policy can be viewed at: https://www.wix.com/about/privacy

20.Control over your own information

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal information changes.

At any time you may contact us to request that we provide you with the personal information we hold about you.

When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

21.Encryption of data sent between us

We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.

Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

22.Communicating with us

When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.

We may keep personally identifiable information associated with your message, such Identity Information and Contact Information so as to be able to respond to you.

23.Use of our website by children

We do not sell products or provide services for purchase by children, nor do we market to children.

If you are under 18, you may use our website only with consent from a parent or guardian.

We collect data about all users of and visitors to these areas regardless of age, and we anticipate that some of those users and visitors will be children.

24.Complaints regarding content on our website

We attempt to moderate user generated content, but we are not always able to do so as soon as that content is published.

If you complain about any of the content on our website, we shall investigate your complaint.

If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.

Free speech is a fundamental right, so we have to make a judgment as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.

If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.

25.Complaints about our products or services

When we receive a complaint, we record all the information you have given to us. We use that information to resolve your complaint.

If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.

We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.

26.How you can complain about this policy

If you are not happy with our privacy policy or if have any complaint then you should tell us by email. 

If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.

If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner's Office (ICO). This can be done at https://ico.org.uk/make-a- complaint/. We would, however, appreciate the opportunity to talk to you about your concern before you approach the ICO.

27.Retention period for personal data

Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:

● to provide you with the services you have requested

● to comply with other law, including for the period demanded by our tax authorities

● to support a claim or defence in court

28.Compliance with the law

Our privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you.

However, ultimately it is your choice as to whether you wish to use our website.

29.Review of this privacy policy

We may update this privacy notice from time to time as necessary. We advise you to print a copy for your records. 

If you have any questions regarding our policy, please contact us.