Privacy & Cookies
Detox Trading 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 when you visit our website (regardless of where you visit if from) and tell you about your privacy rights and how the law protects you.
This privacy notice is split into the sections detailed below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
- Important information and who are are
- The data we collect about you
- How is your personal data collected
- How we use your personal data
- Disclosures of your personal data
- International transfers
- Data security
- Data retention
- Your legal rights
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Detox Trading collects and processes your personal data through your use of this website, 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 and we do not knowingly collect data relating to 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.
|Data Controller:||Detox Trading is the controller and is responsible for your personal data (collectively referred to as Detox Trading “we”, “us” or “our” in this privacy notice).|
|Data Protection Officer:||We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Protection Officer using the details set out below.|
|Our full details are:|
Full name of legal entity: Detox Trading Limited
Data Protection Officer: Paul Harvey
Email address: [email protected]
Postal address: 10 Huxhams Cross, Dartington,
Totnes, TQ9 6NT
Telephone number: 01803 762368
|Complaints:||You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.|
|Changes to the privacy notice and your duty to inform us of change:||This version was last updated on 21st May 2018 and historic versions are archived and can be distributed on request.|
The data protection law in the UK will change on 25 May 2018. Although this privacy notice sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until May 2018 as we are still working towards getting our systems ready for some of these changes.
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.|
2. 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 which we have grouped together follows:
|Data Categories||Examples include|
|Identity Data||first name, maiden name, last name, username or similar identifier, title.|
|Contact Data||billing address, previous address(es), email address and telephone numbers.|
|Financial Data||bank account and payment card details|
|Transaction Data||includes details about payments to and from you, amounts you owe us or we owe you, how you pay us, when your contracts started and ended with us and other details of products and 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 this website.|
|Profile Data||includes your username and password, memorable words and/or answers, purchases or orders made by you, your interests, preferences, feedback, survey responses and consumption data.|
|Marketing and Communications Data||includes your preferences in receiving marketing from us and our third parties and your communication preferences.|
|Usage Data||includes information about how you use our website, products and services.|
|Special Category Data||in limited circumstances health details (there are special rules in relation to this).|
3. 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:
- Apply for our products or services;
- Create an account on our website;
- Subscribe to our service or publications;
- Request marketing to be sent to you;
- Enter a competition, promotion or survey; or
- Give us some feedback.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources worldwide as set out below:
|Technical Data||(a) Analytics providers|
(b) Advertising networks
(c) Search information providers
|Contract Data, Financial Data and Transaction Data||From providers of technical, payment and delivery services, such as credit reference agencies and price comparison websites etc.|
|Identity Data and Contact Data||From data brokers or aggregators.|
|Identity Data and Contact Data|| |
From publicly available sources such as; Companies House, Electoral Register, Land Registry.
From price comparison website partners and other partners.
4. 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.
See table in section 2 to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by logging in to the ‘My Account‘ section of the website.
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 the basis of legitimate interest|
|To register you as a new customer||(a) Identity|
|Performance of a contract with you|
|To process payments under your Contract with us including:|
(a) manage payments, fees and charges
(e) Marketing and Communications
|(a) Performance of a contract with you|
|To manage our relationship with you which will include:|
(b) Asking you to leave a review or take a survey
(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 (to keep our records updated and to study how customers use our products/services)
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity|
(e) Marketing and Communications
|(a) Performance of a contract with you(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity|
|(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|
(e) Marketing and Communications
|(a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) but we will always obtain consents as required by law|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical|
|(a) 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)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity|
|(a) Necessary for our legitimate interests (to develop our products/services and grow our business) but we will always obtain consents as required by law|
Special Categories of data – please refer to the table in section 2 for what we mean by this and what grounds we rely on to process your personal data.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can change your contact preferences by logging into your ‘My Account’ where you can view and make certain decisions about your personal data. If you don’t have an online account, these preferences can be updated by calling us.
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 to you (we call this marketing).
You will receive marketing communications from us if you have requested information from 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 other company for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by logging into ‘My Account‘ and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time. If you are no longer a customer of ours and wish to opt out or update these preferences, this can be done by calling us.
Change of purpose for using your personal data
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
|External Third Parties||Service providers acting as processors who provide IT and system administration services.|
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
To government or regulatory bodies and other authorities acting as processors or joint controllers or independent controllers who require us to help prevent and detect fraud or loss.
To price comparison websites and their licensees acting as independent data controllers who provide a means of introducing customers via their websites for customers wishing to switch suppliers.
To credit reference agencies acting as joint controllers who provide credit referencing services.
To industry operatives acting as joint or independent controllers who provide meter installation, maintenance and reading meters and the industry infrastructure providers such as Elexon, XoServe, Electralink and the DCC.
|Other Third Parties||Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new customers may use your personal data in the same way as set out in this privacy notice.|
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. 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.
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.
8. Data retention
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, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
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.
9. 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.|
|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 or erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.|
|Object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party)||If 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 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 our data but we need to verify whether we have overriding legitimate grounds to use it.|
|Request 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 01803 762368
No fee usually required
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. Alternatively, we may refuse to comply with your request in these circumstances.
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.
|Comply with a legal or regulatory obligation||Means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.|
|Legitimate Interest||Means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to be law). You can obtain further information about how we assess out legitimate interests against any potential impact on you in respect of specific activities by contacting us.|
|Performance of Contract||Means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.|
As of the 26th of May 2012, the European Union has mandated a new regulation which requires website visitors to opt in to having their user behaviour recorded in the form of cookies. To comply with this new e-Privacy Directive, we need to ask for your consent to set these cookies.
Some of the cookies we may use are essential for parts of the site to operate. These are first party cookies and any that we use will be listed in our Schedule 1 table. You may delete and block these cookies from this site, but parts of the site might not work. These cookies allow us to distinguish you from other users of our website, which helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
Other cookies we use are “analytical” cookies. These may be first party cookies or third party cookies. These are listed below in our Schedule 2 table. They allow us to recognise and count the number of visitors and to see how visitors move around the site when they are using it. This helps us to improve the way our website works, for example by ensuring that users are finding what they are looking for easily. These Cookies are not integral to the services provided by the website to you and may be blocked by you.
Schedule 1: First-Party Cookies
|Name of Cookie||Purpose|
|This is a First Party Cookie used to track visitors to our website through our systems to ensure any promotional offers are correctly applied. This cookie automatically expires 30 days after you have visited the relevant promotional landing page for the first time.|
Schedule 2: Third-Party Cookies
|Name of Cookie||Name of Provider||Purpose|
|Google Analytics||To collect anonymous traffic data. See details below|
Google Analytics sets the following cookies as described in the table below. A default configuration and use of Google Analytics sets only the first 4 cookies in the table.
|__utma||This cookie is typically written to the browser upon the first visit to your site from that web browser. If the cookie has been deleted by the browser operator, and the browser subsequently visits your site, a new __utma cookie is written with a different unique ID. This cookie is used to determine unique visitors to your site and it is updated with each page view. Additionally, this cookie is provided with a unique ID that Google Analytics uses to ensure both the validity and accessibility of the cookie as an extra security measure.||2 years from set/update.|
|__utmb||This cookie is used to establish and continue a user session with your site. When a user views a page on your site, the Google Analytics code attempts to update this cookie. If it does not find the cookie, a new one is written and a new session is established. Each time a user visits a different page on your site, this cookie is updated to expire in 30 minutes, thus continuing a single session for as long as user activity continues within 30-minute intervals. This cookie expires when a user pauses on a page on your site for longer than 30 minutes. You can modify the default length of a user session with the_setSessionCookieTimeout() method.||30 minutes from set/update.|
|__utmc||This cookie is no longer used by the ga.js tracking code to determine session status. Historically, this cookie operated in conjunction with the __utmb cookie to determine whether or not to establish a new session for the user. For backwards compatibility purposes with sites still using the urchin.js tracking code, this cookie will continue to be written and will expire when the user exits the browser. However, if you are debugging your site tracking and you use the ga.js tracking code, you should not interpret the existence of this cookie in relation to a new or expired session.||Not set.|
|__utmz||This cookie stores the type of referral used by the visitor to reach your site, whether via a direct method, a referring link, a website search, or a campaign such as an ad or an email link. It is used to calculate search engine traffic, ad campaigns and page navigation within your own site. The cookie is updated with each page view to your site.||6 months from set/update.|
|__utmv||This cookie is not normally present in a default configuration of the tracking code. The __utmv cookie passes the information provided via the _setVar() method, which you use to create a custom user segment. This string is then passed to the Analytics servers in the GIF request URL via the utmcc parameter. This cookie is only written if you have added the _setVar() method for the tracking code on your website page.||2 years from set/update.|
|__utmx||This cookie is used by Website Optimizer and only set when the Website Optimizer tracking code is installed and correctly configured for your pages. When the optimizer script executes, this cookie stores the variation this visitor is assigned to for each experiment, so the visitor has a consistent experience on your site. See the Website Optimizer Help Centerfor more information.||2 years from set/update.|