Here at Free From Pain, we endeavour to protect your privacy and personal data. The following statements will inform you as to how we look after your personal information when you visit our website. This privacy notice will also tell you about your privacy rights and how the law protects you.
1. Important Information and Who We Are
This privacy notice aims to tell you how Free From Pain collects, processes and stores your personal data when using this website, including any data you may provide to this website when purchasing a product.
Third Party Links
Freefrompain.org.uk may contain links to third party websites, applications and plug-ins. Using these links may connect you to third parties who may then collect and share your data. We are not responsible for these third-party websites nor are we responsible for their privacy statements.
The controller responsible for your personal information and data is Free From Pain (collectively referred to as “Free From Pain, “we”, “us” or “our” in this privacy notice).
Data Protection Officer (DPO)
A DPO is a data protection officer who is answerable to any questions regarding this privacy notice. If you do have any questions in relation to this, including your legal rights, please contact the DPO. The contact details are as follows:
Name: Dr. George Ampat
Email Address: firstname.lastname@example.org
Postal Address: Free From Pain, 681 Liverpool Road, Southport, Merseyside, PR8 3NS.
Information Commissioners Office
The Information Commissioners Office is the UK supervisory authority for issues regarding data protection. The website is www.ico.org.uk. You have the right to make a complaint to this office at any time. However, we may be able to deal with your concerns ourselves. We would therefore be grateful if you could give us the opportunity to do so by contacting us before approaching the ICO.
2. The Data We Collect About You
Personal data/information is any information which can identify an individual. Data where identity has been removed, known as anonymous data, is not included. Free From Pain may collect, store, transfer and use various forms of personal data including the following groups:
Includes first & last names, username/identifier, title, gender and date of birth.
Includes delivery & billing address, telephone numbers & email address.
Includes payment card details or PayPal details.
Includes details about payments between you and ourselves. Also includes details of services and products you have purchased from us.
Includes your username and password, purchase/order history, your interests and preferences and your feedback and survey responses.
Includes your login data, browser type / version, internet protocol (IP) address, 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.
Includes information on how you use our website, products and services.
Marketing & Communications Data
Includes your communication preferences and your preferences in receiving marketing from ourselves or our third parties.
We may also collect, use and share Aggregated Data, including demographic and statistical data, for any intention. For instance, we may aggregate your Technical Data to calculate where the majority of our customers are from. Although derived from your personal data, Aggregated Data does not directly or indirectly reveal your identify and is therefore not considered personal data by law. However, if we combine or connect your Aggregated Data to your personal data in a way where it can directly or indirectly identify you, then we will treat this combined data as personal data. It will therefore be used in accordance with this privacy notice.
We will not collect any sensitive data about you. This includes details about your race or ethnicity, sex life or orientation, political, religions or philosophical beliefs, trade union membership, health information and biometric and genetic data. Furthermore, we do not collect any information about criminal offences and convictions.
3. How is your personal data collected?
There are various methods through which we collect your personal data. These include:
You may provide your Identity, Financial and Contact Data when completing forms or by contacting us by phone, post, email etc. You may provide this data when you:
• Generate an account on our website
• Purchase our products or services
• Provide us with feedback
• Subscribe to our publications or services
• Enter a competition, promotion or survey
• Request marketing to be sent to you.
Automated interactions or technologies
Third parties or publicly available sources
Free From Pain may receive your personal data from various third parties including:
• Identity and Contact data from data aggregators or brokers.
• Contact, Financial and Transaction data from technical, payment and delivery service providers based outside of the EU. For example PayPal.
• Technical data from the following parties;
o Search information providers such as Google based outside the EU.
o Analytics providers such as Google based outside the EU.
o Advertising networks such as Facebook based outside the EU.
4. How We Use Your Personal Data
Free From Pain will be lawful in our use of your personal data. We will only use it when the law allows us to. The most common circumstances in which we will use your personal data are:
• When we are to fulfil the obligations of a contract that we are about to enter or have entered with you.
• When we need to comply with a regulatory or legal obligation.
• When it is required for the legitimate interests of you, a third party or ourselves and fundamental rights to not override those interests.
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.
Purposes for Which We Will Use Your Personal Data
The following table sets out 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.
Please 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. Feel free to 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 basis of legitimate interest
To register you as a new customer (a) Identity;
(b) Contact. Performance of a contract with you.
(a) Where you make a booking, to process and deliver your booking including:
(b) Manage payments, fees and charges;
Collect and recover money owed to us. (a) Identity;
(e) Marketing and Communications. (a) Performance of a contract with you;
(b) Necessary for our legitimate interests (to recover debts due to us).
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey. (a) Identity;
(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;
(c) Technical. (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;
(d) Technical ; 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)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical
(b) Usage 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
(e) Profile Necessary for our legitimate interests (to develop our products/services and grow our business)
In order to decide what products, services and offers might be relevant to you we may use your Identity, Contact, Technical, Usage and Profile Data. This is to form a view on what we think you may want or need, or what may be of interest to you.
You will receive marketing communications from us if you have requested information from us or purchased goods from us and if you have not opted out of receiving marketing. You will also receive marketing communications from us if you provide us with your details when entering a competition or registering for a promotion and, again, 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 of Free From Pain for marketing purposes.
You can ask us or third parties to stop sending you marketing messages. Do this by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a purchase, or other transactions.
What is a cookie?
A cookie is a piece of information that is stored on your computers hard drive. It records how you move around a website and stores that information in what is essentially a tiny file. They are used to improve your online user experience. When you next visit that website, the information (cookie) is used to present options tailored for you.
There are two types of cookies:
Essential Cookies: These cookies are required for the proper functioning of the website. They include cookies used for the general administration and management of the signup process. They are also used to remember that your computer is ‘logged in’, so that you do not have to log in every time you visit a new page. These cookies are normally deleted when you log out. However, they will sometimes remain in order to remember your site preferences. Cookies are also required to remember the items in your basket and form an essential part of the checkout process.
Third Party Cookies: Google Analytics? Social Media? Facebook Pixel?
Change of Purpose
Free From Pain will typically only use your personal data for the purposes for which we collected it. However, we may use it for another reason if we have reasonable need to and if that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will inform you and we will make clear the legal basis which enables us to do so.
Please note that, in compliance with the above rules and where required or permitted by law, we may process your personal data without your knowledge or consent.
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:
• Service providers who provide IT and system administration services.
• Professional advisers including bankers, lawyers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
• Third parties, to whom we may choose to merge, transfer or sell parts of our business or our assets. 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
Some of our external third parties are based outside the European Economic Area (EEA). Therefore, 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 will make certain that a similar level of protection is afforded to it.
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 date for?
We will only keep 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.
By law we are 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 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:
• Request access to your personal data (data subject access request).
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us using the contact details stated above.
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.
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.
Time 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.