Effective Date 14.09.18
David Ragg Florist Ltd trading as BORN TO BLOOM
Born to Bloom cares deeply about the privacy of its visitors and users, and is fully committed to protect their personal information and use it properly in compliance with data privacy laws. This policy describes how we may collect and use personal information, and the rights and choices available to our visitors and users regarding such information.
1. Information we collect
1.1. Visitor and User Information
We collect two types of information: Personal Information (which could be used to uniquely identify an individual) and Non-personal Information (which is non-identifying).
The Non-personal Information collected by us mainly consists of technical and aggregated usage information, such as Visitors’ and Users’ browsing on our Services, session heatmaps and scrolls, non-identifying information regarding the Visitor’s or User’s device, operating system, internet browser, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, etc. This non personal information is collected automatically and does not enable us to identify the Visitor or User from whom it was collected.
The Personal Information collected by us mainly consists of contact details (e.g., e-mail address or phone number), billing details (name, physical billing address, payment method and transaction details), which are only collected from Users with Paid Services, details regarding a browsing or usage session (IP address, Geo-location and/or device unique identifier), correspondences (including those made through or uploaded to our Services), and any other Personal Information provided to us by Visitors and/or Users through their access to and/or use of the Services. For the avoidance of doubt, any Non-personal Information that is connected or linked to Personal Information (for example, in order to improve the Services we offer) is deemed and treated by us as Personal Information, as long as such connection or linkage exists.
1.2. Users of Users Information
We may also collect similar information pertaining to visitors and users of our User’s websites or services (“Users-of-Users”), solely for and on our Users’ behalf (as further described in Section 6below).
1.3 Job Applicant Information
We also collect information that is provided to us by job candidates, when they apply to any of the open positions.
2. Information Collection
There are two main methods we use:
We collect information through your use of the Services. When you visit or use our Services, including when you browse the Website or any User Website, register a User Account, edit your User Website and upload information and content we are aware of it and will usually gather, collect and record such uses, sessions and related information, either independently or with the help of third-party services as detailed in Section 8 below, including through the use of “cookies” and other tracking technologies, as further detailed in Section 9 below.
We collect information which you provide us voluntarily. For example, we collect the Personal Information you provide us when you register to our Services; when you sign in to our Services via third party services such as Facebook or Google; when you place purchases; when you submit or upload such Personal Information as you use any of our Services; and/or when you contact us directly by email.
3. Information Usage
We collect such Non-personal and Personal Information for the following purposes:
To provide and operate the Services;
To further develop, customise and improve our Services, based on Visitors’ and Users’ common or personal preferences, experiences and difficulties;
To provide our Users with ongoing customer assistance and technical support;
To be able to contact our Visitors and Users with general or personalised service-related notices and promotional messages (as further detailed in Section 10 below);
To create aggregated statistical data and other aggregated and/or inferred Non-personal Information, which we may use to provide and improve our respective services;
To enhance our data security and fraud prevention capabilities;
To consider Applicants’ for a job vacancy.
To comply with any applicable laws and regulations.
We will only use your Personal Information for the purposes set out in Section 3 where we are satisfied that:
Our use of your Personal Information is necessary to perform a contract or take steps to enter into a contract with you (e.g. to provide you with a website, to provide you with our customer assistance and technical support), or
Our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have.
Our Services are not permitted to children under 18 years of age. No one under age 18 should provide any Personal Information to us through any of our Services. We do not knowingly collect Personal Information from children under 18. Parents and guardians should supervise their children's activities at all times.
4. Information Storage
Born to Bloom Visitors’ and Users’ Personal Information may be stored by Born to Bloom and service providers in the United Kingdom and United States of America for the proper delivery of our Services and/or as may be required by law.
Upon request Born to Bloom will provide you with information about whether we hold any of your Personal Information. As per GDPR in the EU you may request access, correct, or request deletion of your Personal Information by contacting Born to Bloom via the contact details below. We will respond to your request within a timeframe imposed by local laws or a reasonable timeframe.
Please note that permanently deleting your Born to Bloom account erases all of your information from Born to Bloom’s databases. After completing this process, you can no longer use any of the Born to Bloom Services, your User Account and all its data will be removed permanently, and Born to Bloom will not be able to restore your account or retrieve your data in the future. If you contact Born to Bloom in the future, the system will not recognise your account and Support agents will not be able to locate the deleted account.
5. Users-of-users' Information
Born to Bloom may collect, store and process certain Non-personal and Personal Information of Users-of-Users (“Users-of-Users Information”), solely on our Users’ behalf and at their direction. For example, each of our Users is able to manage contacts via their User Website. Such contacts are then stored with Born to Bloom, on the User’s behalf.
For such purposes, Born to Bloom serves and shall be considered as a “Processor” and not as the “Controller” (as both such capitalised terms are defined in the European Union General Data Protection Regulation) of such Users-of-Users Information. The Users controlling and operating such User Websites shall be considered as the “Controllers” of such Users-of-Users Information, and are responsible for complying with all laws and regulations that may apply to the collection and control of such Users-of-Users Information, including all privacy and data protection laws of all relevant jurisdictions.
You are responsible for the security, integrity and authorised usage of your Users-of-Users’ Personal Information, and for obtaining consents, permissions and providing any fair processing notices required for the collection and usage of such information.
Born to Bloom cannot provide legal advice to Users or their Users-of-Users, however we do recommend that all Users publish and maintain clear and comprehensive privacy policies on their User Websites, in accordance with the applicable laws and regulations, and that all Users-of-Users carefully read those policies and make sure that they consent to them.
If you are a visitor, user or customer of any of our Users, please read the following: Born to Bloom has no direct relationship with the individual Users-of-Users whose Personal Information it processes. If you are a visitor, user or customer of any of our Users, and would like to make any requests or queries regarding your Personal Information, please contact such User(s) directly. For example, if you wish to access, correct, amend, or delete inaccurate information processed by Born to Bloom on behalf of its Users, please direct your query to the relevant User (who is the “Controller” of such data). If requested to remove any Users-of-Users’ Personal Information, we will respond to such request within thirty (30) days.
6. Sharing personal information with third parties
Born to Bloom may share your Personal Information with third parties (or otherwise allow them access to it) only in the following manners and instances:
6.1. Third Party Services:
Born to Bloom use a few 3rd party providers whose services and solutions complement, facilitate and enhance our service. These include hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, domain name registrars, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, performance measurement, data optimisation and our legal and financial advisors (collectively, “Third Party Service(s)”). Such Third Party Services may receive or otherwise have access to our Visitors’ and Users’ Personal Information and/or Users-of-Users’ Personal Information, in its entirety or in part – depending on each of their particular roles and purposes in facilitating and enhancing our Services and business, and may only use it for such purposes.
6.2. Law Enforcement, Legal Requests and Duties:
Where permitted by local data protection laws, Born to Bloom may disclose or otherwise allow others access to your Personal Information pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have good faith belief that the law requires us to do so, with or without notice to you.
6.3. Protecting Rights and Safety:
Born to Bloom may share your Personal Information with others if we believe in good faith that this will help protect the rights, property or personal safety of Born to Bloom, any of our Users, any Users-of-Users, or any member of the general public, with or without notice to you.
6.4. Social Media Features and Framed Pages:
Our Services include certain Social Media features and widgets, single sign on features, such as the “Facebook Connect” or “Google Sign-in”, the “Facebook Like” button, the “Share this” button or other interactive mini-programs (“Social Media Features”).These Social Media Features may collect information such as your IP address or which page you are visiting on our Website, and may set a cookie to enable them to function properly. Social Media Features are either hosted by a third party or hosted directly on our Services. Your interactions with these third parties’ Social Media Features are governed by their policies and not ours.
In addition, our Services may enable you to share your Personal Information with third parties directly, such as via page framing techniques to serve content to or from Third Party Services or other parties, while preserving the look and feel of our Website and Services (“Frames”). Please be aware that if you choose to interact or share any Personal Information via such Frames, you are in fact providing it to these third parties and not to us, and such interactions and sharing too are governed by such third parties’ policies and not ours.
We may use your Personal Information to send you promotional content and messages by e-mail, calls and similar forms of communication.
If you do not wish to receive such promotional messages or calls, you may notify Born to Bloom at any time or follow the “unsubscribe” or STOP instructions contained in the promotional communications you receive. Please note if you choose to unsubscribe from these messages this would include messages such as relay service product updates.
8.2. Service and Billing Messages:
Born to Bloom may also contact you with important information regarding our Services, or your use thereof. For example, we may send you a notice (through any of the means available to us) if a certain Service is temporarily suspended for maintenance; reply to your support ticket or e-mail; send you reminders or warnings regarding upcoming or late payments for your current or upcoming subscriptions; forward abuse complaints regarding your User Website; or notify you of material changes in our Services.
It is important that you are always able to receive such messages. For this reason, you are not be able to opt-out of receiving such Service and Billing Messages unless you are no longer a Born to Bloom User (which can be done by deactivating your account).
9. Your rights in relation to your personal information
It is imperative that you have control over your Personal Information which is why we enable you to receive a copy of, update, amend, delete, or limit the use of your Personal Information.
Before disclosing the requested Personal Information, we may ask you for additional information in order to confirm your identity and for security purposes. We reserve the right to charge a fee where permitted by law (e.g., if your request is unfounded or excessive).
You have the right to file a complaint with your local supervisory authority for data protection (but we still recommend that you contact us first).
If you are a Born to Bloom Visitor or User, and you wish to receive a copy, access and/or request us to make corrections to the Personal Information that you have stored with us (either yours or your Users-of-Users’), or wish to request a list of what Personal Information (if any) pertaining to you we disclosed to third parties for direct marketing purposes. We will make all reasonable efforts to complete your request promptly (unless we require further information from you in order to fulfil your request), subject to legal and other permissible considerations. ?
10. Data Retention
We may continue to retain such Personal Information even after you deactivate your User Account and/or cease to use any particular Services, as reasonably necessary to comply with our legal obligations, to resolve disputes regarding our Users or their Users-of-Users, prevent fraud and abuse, enforce our agreements and/or protect our legitimate interests. We maintain a data retention policy which we apply to information in our care. Where your Personal Information is no longer required we will ensure it is securely deleted.
Securing your personal information, and use various security measures to better protect it.
However, as we can’t guarantee absolute protection – we encourage you to be careful, set a strong password for your account, and avoid submitting any sensitive information which, if exposed, could cause you major harm.
12. Updates and Interpretation
13. Contacting Us