Privacy Policy & GDPR Commitment

Last Updated: August 14, 2020

IMPORTANT INFORMATION AND WHO WE ARE
This privacy policy (“Policy”) describes how Flora & Curl Ltd (also referred to as “Flora and Curl” or “Flora & Curl”) and its related companies (“Company”) collect, use and share personal information of consumer users of this website: www.floracurl.com (the “Site”).

Protecting personal information is one of Flora & Curl's core values. This Privacy Policy describes how Flora & Curl collects, uses, and discloses the personal information we receive, that you provide or that you make available to us. It also describes your choices.

Third-party links
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 this website, we encourage you to read the privacy notice of every website you visit.


INFORMATION WE COLLECT ABOUT YOU
Information You Give Us. We collect your‎ name, postal address, email address, phone number, username, password, demographic information (such as your gender), social media account ID, as well as other information that you directly give us on our Site. We use this information to send you offers or other voluntary communications with Flora & Curl. We never sell this information to a third party. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name and last name.
  • Contact Data includes physical address, email address, fax number and telephone numbers.
  • Technical Data includes 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.
  • Usage Data includes information about how you use our website and the features you interact with on our website, our products and our services and information you submit to us in relation to any support issues.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties, your interactions with our marketing communications and your communication preferences.
  • Financial Data includes bank account and/or payment card details.
  • Transaction Data includes details about payments to and from Flora & Curl and other details of products and services you have purchased from Flora & Curl.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Information We Get From Others. We may get information about you from other sources, including our order processing partners, Shopify, Global-E and Paypal, to facilitate purchasing and orders on our site. Additionally, when you make a purchase or attempt to make a purchase through the Site, Flora & Curl and/or our partners collect certain information from you, including your name, billing address, shipping address, payment information (including credit card), email address, and phone number.  We refer to this information as “Order Information.”

Information Automatically Collected. We automatically log information about you and your computer. For example, when visiting our Site, we log your computer operating system type, browser type, browser language, the website you visited before browsing to our Site, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Site.

COOKIES
We may log information using "cookies". Cookies are small data files stored on your hard drive by a website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site.  This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your special interests and needs.

When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information”.

We collect Device Information using the following technologies: 

  • “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org. 
  • “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps. 
  • “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site.

When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Order Information.

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of this website. They include, for example, cookies that enable you to log into secure areas of our website, submit comments to our blog or use submission forms

Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website 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.

Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you to remember your preferences (for example, your choice of language or region).

Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.


HOW WE USE YOUR PERSONAL INFORMATION

We use the Order Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally:

  • We use your personal information to operate, maintain, and improve our sites, products, and services.
  • We use your personal information to process and deliver contest entries, rewards, and discounts.
  • We use your personal information to respond to comments and questions and provide customer service.
  • We use your personal information to send information including confirmations, shipping, technical notices, updates, security alerts, and support and administrative messages.
  • We use your personal information to communicate about promotions, upcoming events, and other news about products and services offered by us and our selected partners.
  • We use your personal information to link or combine user information with other personal information.
  • We use your personal information to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
  • We use your personal information to provide and deliver products and services customers request.

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).


SHARING YOUR PERSONAL INFORMATION 

We share your Personal Information with third parties to help us use your Personal Information, as described above. In addition:

  • We may share personal information with your consent. For example, you may let us use your personal information to facilitate an order or for marketing purpose.
  • We may share personal information when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
  • We may share personal information for legal, protection, and safety purposes.
  • We may share information to protect the rights and property of Flora & Curl, our agents, customers, and others. This includes enforcing our agreements, policies, and terms of use.
  • We may share information in an emergency. This includes protecting the safety of our employees and agents, our customers, or any person.
  • We may share information with those who need it to do work for us.

For example, we use Shopify to power our online store. You can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy.

We also use Google Analytics to help us understand how our customers use the Site -- you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.


BEHAVIOURAL ADVERTISING AND MARKETING

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by using the links below: 

  • Facebook: https://www.facebook.com/settings/?tab=ads 
  • Google: https://www.google.com/settings/ads/anonymous 

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.
 

OPTING OUT
Our marketing emails tell you how to “opt-out.” If you opt out, we may still send you non-marketing emails. You can unsubscribe your email from our newsletter via any of our digital newsletters you receive. The link to change your preferences can usually be found at the bottom of the emails you receive from us. Non-marketing emails include emails about your accounts, bookings, and our business dealings with you. 

You can typically remove and reject cookies from our Site with your browser settings. Many browsers are set to accept cookies until you change your settings. If you remove or reject our cookies, it could affect how our Site works for you.

Change of purpose
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.


BLOCKING COOKIES
You may block cookies by activating settings on your browser which allow you to refuse the setting of some or all cookies. If you do so choose to block all cookies (including essential cookies) you may not be able to access all or some parts of our website. 

Most cookies we use are known as session cookies. These cookies will expire whenever you close your browser or shut down your computer, and such cookies need not be blocked. Other cookies used for specific purpose will expire when that purpose is no longer required.

You can find out more about blocking cookies in specific browsers at http://aboutcookies.org.

DO NOT TRACK 
Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

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.

Flora & Curl takes reasonable precautions to protect personal data relating to individuals which is processed and collected by Flora & Curl. Flora & Curl applies generally accepted industry standard security measures to such personal data and protect it from unauthorized access or against loss, misuse or alteration by third parties.

Although we make good faith efforts to store personal data in a secure operating environment that is not available to the public, we cannot guarantee the absolute security of personal data during its transmission or its storage on our systems. 

Further, while we make every effort to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers” from illegally obtaining access to this information. 

We do not warrant or represent that personal data will be protected against, loss, misuse, or alteration by third parties.


PAYMENT

If you provide us with your credit card information, the information is encrypted using secure socket layer technology (SSL) and stored with a AES-256 encryption. Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements and implement additional generally accepted industry standards.

If you choose a direct payment gateway to complete your purchase, then Shopify stores your credit card data. It is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction. After that is complete, your purchase transaction information is deleted. 

All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. 

PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers. 
For more insight, you may also want to read Shopify’s Terms of Service (https://www.shopify.com/legal/terms) or Privacy Statement (https://www.shopify.com/legal/privacy).

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.

Details of retention periods for different aspects of your personal data can be requested from us by contacting us.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax purposes.

In some circumstances we may aggregate your personal data (so that it can no longer be associated with you) for research or statistical purposes.


YOUR LEGAL RIGHTS: REQUEST AND DELETE DATA
Under the EU GDPR Laws that came into effect on 25/05/2018, subscribers have a Right To Be Forgotten. If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted.

Additionally, if you are a European resident we note that we are processing your information in order to fulfil contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above.

  • Request access to your personal data: this enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. This is commonly known as a "data subject access request".
  • Request correction of your personal data: 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 can also 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.
  • 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 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 transfer of your personal data: we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. (Note: 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.)

If you wish to exercise any of the rights set out above, please contact us.

You can always send us an email via hello@floracurl.com and request any of the above, including that your data be permanently deleted (deletion includes purchase information and historical details). 

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.

Where we are not able to determine with any degree of certainty whether the information requested by you relates exclusively to you, our disclosure of such information to you may pose a privacy risk to a third party (for example, where a cookie is associated with a device used by more than one person). We will assess each request to exercise any of the rights listed above individually on its merits and will disclose the requested information where we are satisfied that such disclosure does not represent a privacy risk to any third party.

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.

MINORS 
The Site is not intended for individuals under the age of 13. Minors may use the Site only with the assistance of a parent or guardian. 

CHANGES TO OUR PRIVACY POLICY
We may change this policy from time to time. Although we will strive to ensure that any such changes are small, and we will inform you and, if appropriate, seek your consent if we intend to materially change the way in which we use your data. We recommend that you consult this privacy policy regularly for updates. If we make any changes, we will change the ''Last Updated'' date above. 

OWNER AND DATA CONTROLLER
If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information, please contact our Date and Privacy Controller at hello@floracurl.com or by post at:

Flora & Curl Haircare
FAO: Data and Privacy Controller
Apex House
3 Embassy Drive
Calthorpe Road
Birmingham
B15 1TR, United Kingdom

Flora & Curl Ltd. UK Company number: 10493194