SENTIMA respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects to you.
Purpose of this privacy notice
SENTIMA is made up of different legal entities. This privacy notice is issued on behalf of each entity of SENTIMA so when we mention ” SENTIMA “, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in SENTIMA responsible for processing your data. The Sentima Club Limited is the controller and responsible for this website.
This privacy notice aims to give you information on how SENTIMA collects and processes your personal data through your use of this website or our services, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service or take part in a competition. This website is not intended for children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us at firstname.lastname@example.org
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 13 July 2020
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.
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 notice of every website you visit.
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 join SENTIMA or place a request for services with us and includes circumstances in which you:
- apply for our products or services;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
- Fill out forms on our site
- Automated technologies or interactions. As you interact with our website, we may automatically collect 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.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from analytics providers such as Google based outside the EU.
- Identity and Contact Data from publicly availably sources
THE 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 such as:-
- Information that you provide to us when you register to be a member or fill out forms on a Site. You acknowledge that, where registering to use certain of our services, you may be required to submit “sensitive” personal information (such as information regarding your physical condition, ethnic origin, sexual orientation and religious beliefs) and consent to our processing of such information in accordance with this privacy promise;
- Information that you submit when you place an order for our services (including your name, email address, delivery address, credit or debit card number and expiration date) which we need to process your order and to notify you of your order status;
- Information about you which you include in any e-mails or letters that you send to us;
- Information about your usage of the Site; and
- Information about your computer, which may include your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers (statistical data about’ browsing actions and patterns that does not identify any individual).
- Information about your preferences in receiving marketing from us and our third parties and your communication preferences
If you fail to provide personal data
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.
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you
- 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.
- Where we need to comply with a legal or regulatory obligation.
- To ensure that content from our Sites is presented in the most effective manner for you and your computer;
- To provide customer service to you in relation to your use of a Site, to deal with enquiries and complaints relating to the use of a Site;
notify you every now and again about important changes to the Sites or our services:-
- To administer, support, improve, optimise and develop our Sites (including any advertising present on our Sites);
- To produce reports on our customers’ preferences, interests and buying habits (these reports will not identify you in any way); and
for security purposes.
- We may also use your information to notify you of our services and our exciting new offers if you have either requested marketing communications from us, or consented to receive marketing communications when you registered for one of our services. If you do not want to receive such marketing communications, please tick the appropriate box on the relevant Site’s registration page. You may opt out of receiving such marketing communications at any time.
- We may permit selected third party partners or affiliates of ours to provide you with information about their products and services which maybe of interest to you, as long as you have consented to receive marketing communications from our selected third parties for such purposes.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to 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.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:
Promotional offers from us
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 (we call this marketing).
You will receive marketing communications from us if you have requested information from us or placed a request with us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside SENTIMA for marketing purposes.
You may opt out from receiving marketing communications at any time by notifying us in writing, contacting us at email@example.com or, alternatively, by following the procedure to ‘unsubscribe’ that is specified in any marketing email that you receive.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
DISCLOSURES OF YOUR PERSONAL DATA
We may disclose your personal information to any member of our group of companies (which includes any of our subsidiaries).
We may also disclose your personal information:
- To our affiliates, franchisees, suppliers, delivery companies, customers with whom we have contracted to provide services to you and other third parties to whom disclosure is necessary to enable us to process your orders and provide you with any service to which you have subscribed via the Site;
- Where required to do so by law or court order;
- Upon the sale of the business (in which case personal data of our customers will be one of the transferred assets);
- To any person to whom disclosure is necessary to enable us to enforce our rights under this privacy promise or under any of our applicable Terms and Conditions.
We may provide third parties with anonymised reports on our customers’ preferences, interests and buying habits. We may provide our trusted service providers with anonymous information about our customers in order for them to compile these reports on our behalf. These reports will not identify you in any way.
Other than as expressly set out in this privacy promise or as otherwise required or permitted by law, we will not share, sell or distribute any of the information you provide to us without your consent.
We share your personal data within the legal entities of SENTIMA. This may involve transferring your data outside the European Economic Area (EEA).
Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it and ensure any information shared is safeguarded.
All information you provide to us is stored on our secure servers or servers hosted by third party service providers. Any payment transactions will be encrypted using SSL/TLS technology.
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.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, servicing or reporting requirements.
In some circumstances 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.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. We may charge you a small fee for this service.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
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. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. 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 data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data 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 data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us on firstname.lastname@example.org
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data 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.
Time limit to respond
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
We may use an analytics service provider for website traffic analysis and reporting. Analytics service providers generate statistical and other information about website use by means of cookies, which are stored on users’ computers. The information generated relating to the Sites may be used to create reports about the use of the Sites and the analytics service provider will store this information.
If you do not wish for cookies to be installed on your computer, you can change the settings on your internet browser to disable, remove or reject cookies. For more information about how to do this, you should consult the “Help” section of your browser. In some but not all instances, cookies can be blocked in the future by selecting certain settings. Each browser you use will need to be set separately and you will see that different browsers offer different functionality and options in this regard. Please note that rejecting cookies via your browser may not be effective with regard to HMTL5 and Flash cookies (which are explained in more detail above). For information on disabling Flash cookies, please go to Adobe’s website www.adobe.com.