TERMS & CONDITIONS

SUBMITTING YOUR ORDER

To place an order, simply visit drmindellshealth.com and add a product to your basket and then follow the steps given during the checkout procedure. Payment can be made with a variety of payment options and is safely transmitted via SSL. You will receive an order confirmation email once you submit your order. by clicking continue to payment you are agreeing to receive communications which include but are not limited to emails, multimedia messages, telecommunications and other forms of communication. You can opt out at any time by emailing [email protected].

SUBSCRIBE & SAVE

An order placed using the Subscribe & Save offer, is an agreement to a regular monthly payment & shipment service.  Payments are taken monthly and shipments are processed bi-monthly. This subscription can be cancelled at any time.  You are liable for any outstanding payment for goods already received and not returned. You must inform us of your intent to cancel this service within 21 days of your last payment being processed to avoid the next order being processed. Failure to cancel within 21 days of your last payment may result in your next order being dispatched and charged for and you will be responsible for the payment or return of these products for a full refund.

 

VAT EXEMPT PRODUCTS

There are some products on the site which have a qualifying zero VAT rate due to their classification. These product are a VAT exempt product when purchased for use on a chronic or disabling condition such as Osteoarthritis, Arthritis or Sciatica, subject that you have suffered with the condition for at least 3 months. Unfortunately VAT relief is not available for short term conditions and injuries.

If you are unsure if you qualify for exemption please contact our customer care line 0800 036 0270

RIGHT OF CANCELLATION

Under the Consumer Protection Distance Selling Regulations you have a statutory right to cancel your order and receive a full refund.
You can cancel your order up to and including the fourteenth day after receipt.

DELIVERY CHARGES

Delivery charges are included within the total item price as advertised unless clearly stated otherwise, and due to the different services chosen and packaging required will depend on your total order value. The price is as follows:

EU Delivery Charges

• Orders up to £15 – £7.99
• Orders up to £25 – £10.99
• Orders over £25 – £18.99

For orders outside the EU, please contact us for a quotation.

RETURNS

When returning an item, please contact us prior to returning your item so that we can provide you with a return code to ensure a prompt and efficient returns handling. The return address is:

Drmindellshealth Returns Dept
PostBus 7136, 3109 AC Schiedam,
Netherlands

Please note: we do not pay return postage costs unless the item is faulty. This does not affect your statutory rights.

PRIVACY POLICY

This privacy policy sets out how drmindellshealth.com uses and protects any information that you give us when you use the website. The company is committed to ensuring that your privacy is protected at every level. We recommend that you check this page from time to time to ensure that you are happy with any changes made which can be made at any time.

INFORMATION COLLECTED

The website may collect the following information:

• Your name
• Your contact information
• Your demographic information such as preferences and interests
• Any other information relevant to customer surveys and/or offers on the site

INFORMATION GATHERED

We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:

• Internal record keeping.
• We may use the information to improve our products and services.
• We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided.
• From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail. We may use the information to customise the website according to your interests.

MAINTAINING YOUR SECURITY

drmindellshealth.com are committed to ensuring that your information is secure. In order to prevent unauthorised access to your data, we have put in place suitable physical, electronic and management processes to safeguard and secure the information collected.

HOW WE USE COOKIES

What is a cookie? A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, which is more relevant to you and by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. We recommend you consult your web browser documentation to find out how to do this.

LINKS TO EXTERNAL WEBSITES

We may link on this website to other links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting external sites. These external sites are not governed by this privacy statement.

CONTROLLING YOUR PERSONAL INFORMATION

There are ways that you can restrict the collection or use of your personal information in the following ways:

• whenever you are asked to fill in a form on the website you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes
• If you have previously agreed to us using your personal information for direct marketing purposes, you can contact us at any time at [email protected] to remove yourself from such marketing communications.

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.

If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.

This cookies policy sets out how drmindellshealth.com uses cookies to enhance your browsing experience on our website. This goes hand in hand with our privacy policy which you can view here. Last updated on 20 September 2020.

THE COOKIES WE USE

Strictly necessary cookies

These cookies are essential for you to browse the website and use its features, such as accessing secure areas of the site and remembering the items in your basket. These cookies DO NOT track your browsing habits.

The strictly necessary cookies we employ are:

• wc_cart_hash_# – Necessary for the shopping cart functionality on the website.
• wc_fragments_# – Necessary for the shopping cart functionality on the website.
• woocommerce_cart_hash – Necessary for the shopping cart functionality on the website to remember the chosen products. This also allows the website to promote related products to the visitor, based on the content of the shopping cart.
• woocommerce_items_in_cart – Necessary for the shopping cart functionality on the website to remember the chosen products. This also allows the website to promote related products to the visitor, based on the content of the shopping cart.
• wordpress_test_cookie – Used to check if the user’s browser supports cookies.
• wp_woocommerce_session_# – Used by the website to interface with our e-commerce platform.

Statistics cookies

Also known as “performance cookies,” these cookies collect information about how you use our website, like which pages you visited and which links you clicked on. None of this information can be used to identify you. Google Analytics cookies are the majority of cookies we use in this section.

The statistics cookies we employ are:

• _ga – used to generate statistical data on how the visitor uses the website.
• _gat – Used by Google Analytics to throttle request rate
• _gid – used to generate statistical data on how the visitor uses the website.
• tk_ai – Registers data on visitors’ website-behaviour. This is used for internal analysis and website optimization.

Marketing cookies

Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and useful for the user and thereby more valuable for publishers and third party advertisers.

The marketing cookies we employ are:

• _fbp [facebook.com] – Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers.
• eng_mt – Tracks the conversion rate between the user and the advertisement banners on the website – This serves to optimise the relevance of the advertisements on the website.
• fr [facebook.com] – Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers.
• tr [facebook.com] – Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers.
• trctestcookie – Detects whether partner data synchronization is functioning and currently running – This function sends user data between third-party advertisement companies for the purpose of targeted advertisements.

Miscellaneous cookies

We use these third party cookies to provide extra functionality on our website, such as the chat function you see in the bottom right corner of the page.

The third-party cookies we employ are:

• tidio_state_izio6bslkg2uaztbaqqw9xmxcwpn34im – Used by Tidio, our online chat provider.
• tidio_state_izio6bslkg2uaztbaqqw9xmxcwpn34im_widget_position – Used by Tidio, our online chat provider. This cookie stores the position of the chat widget on the webpage.

For more information about cookies, visit http://www.allaboutcookies.org/

GDPR (General Data Protection Regulations) Policy

1. Definitions:

Automated Decision-Making (ADM): when a decision is made which is based solely on Automated Processing (including profiling) which produces legal effects or significantly affects an individual. The GDPR prohibits Automated Decision-Making (unless certain conditions are met) but not Automated Processing.

Automated Processing: any form of automated processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to an individual, in particular to analyse or predict aspects concerning that individual’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements. Profiling is an example of Automated Processing.

Consent: agreement which must be freely given, specific, informed and be an unambiguous indication of the Data Subject’s wishes by which they, by a statement or by a clear positive action, signifies agreement to the Processing of Personal Data relating to them.

Controller: the person or organisation that determines when, why and how to process Personal Data. It is responsible for establishing practices and policies in line with the GDPR. We are the Controller of all Personal Data relating to our Company Personnel and Personal Data used in our business for our own commercial purposes.

Criminal Convictions Data: means personal data relating to criminal convictions and offences.

Data Subject: a living, identified or identifiable individual about whom we hold Personal Data. Data Subjects may be nationals or residents of any country and may have legal rights regarding their Personal Data.

Data Privacy Impact Assessment (DPIA): tools and assessments used to identify and reduce risks of a data processing activity. DPIA can be carried out as part of Privacy by Design and should be conducted for all major system or business change programs involving the Processing of Personal Data.

Data Protection Officer (DPO): the person required to be appointed in specific circumstances under the GDPR. Where a mandatory DPO has not been appointed, this term means a data protection manager or other voluntary appointment of a DPO or refers to the Company data privacy team with responsibility for data protection compliance.

EEA: the 28 countries in the EU, and Iceland, Liechtenstein and Norway.

Explicit Consent: consent which requires a very clear and specific statement (that is, not just action).

General Data Protection Regulation (GDPR): the General Data Protection Regulation ((EU) 2016/679). Personal Data is subject to the legal safeguards specified in the GDPR.

Personal Data: any information identifying a Data Subject or information relating to a Data Subject that we can identify (directly or indirectly) from that data alone or in combination with other identifiers we possess or can reasonably access. Personal Data includes Special Categories of Personal Data and Pseudonymised Personal Data but excludes anonymous data or data that has had the identity of an individual permanently removed. Personal data can be factual (for example, a name, email address, location or date of birth) or an opinion about that person’s actions or behaviour.

Personal Data Breach: any act or omission that compromises the security, confidentiality, integrity or availability of Personal Data or the physical, technical, administrative or organisational safeguards that we or our third-party service providers put in place to protect it. The loss, or unauthorised access, disclosure or acquisition, of Personal Data is a Personal Data Breach.

Privacy by Design: implementing appropriate technical and organisational measures in an effective manner to ensure compliance with the GDPR.

Privacy Guidelines: the Company privacy/GDPR related guidelines provided to assist in interpreting and implementing this Privacy Standard and Related Policies, available here:

Privacy Notices (also referred to as Fair Processing Notices) or Privacy Policies: separate notices setting out information that may be provided to Data Subjects when the Company collects information about them. These notices may take the form of general privacy statements applicable to a specific group of individuals (for example, employee privacy notices or the website privacy policy) or they may be stand-alone, one time privacy statements covering Processing related to a specific purpose.

Processing or Process: any activity that involves the use of Personal Data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring Personal Data to third parties.

Pseudonymisation or Pseudonymised: replacing information that directly or indirectly identifies an individual with one or more artificial identifiers or pseudonyms so that the person, to whom the data relates, cannot be identified without the use of additional information which is meant to be kept separately and secure.

Special Categories of Personal Data: information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data. [The Company also considers the following types of data to be Special Categories of Personal Data:

2. Introduction

This Privacy Standard sets out how Britannic Health Media Ltd (“we”, “our”, “us”, “the Company”) handle the Personal Data of our customers, suppliers, employees, workers and other third parties.

This Privacy Standard applies to all Personal Data we Process regardless of the media on which that data is stored or whether it relates to past or present employees, workers, customers, clients or supplier contacts, shareholders, website users or any other Data Subject.

This Privacy Standard is an internal document and cannot be shared with third parties, clients or regulators without prior authorisation from the DPO.

3. Scope

We recognise that the correct and lawful treatment of Personal Data will maintain confidence in the organisation and will provide for successful business operations. Protecting the confidentiality and integrity of Personal Data is a critical responsibility that we take seriously at all times.

All, are responsible for ensuring all Company Personnel comply with this Privacy Standard and need to implement appropriate practices, processes, controls and training to ensure such compliance.

The DPO is responsible for overseeing this Privacy Standard and, as applicable, developing Related Policies and Privacy Guidelines.

Please contact the DPO with any questions about the operation of this Privacy Standard or the GDPR or if you have any concerns that this Privacy Standard is not being or has not been followed

4. Personal data protection principles

We adhere to the principles relating to Processing of Personal Data set out in the GDPR which require Personal Data to be:

(a) Processed lawfully, fairly and in a transparent manner (Lawfulness, Fairness and Transparency).

(b) Collected only for specified, explicit and legitimate purposes (Purpose Limitation).

(c) Adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed (Data Minimisation).

(d) Accurate and where necessary kept up to date (Accuracy).

(e) Not kept in a form which permits identification of Data Subjects for longer than is necessary for the purposes for which the data is Processed (Storage Limitation).

(f) Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful Processing and against accidental loss, destruction or damage (Security, Integrity and Confidentiality).

(g) Not transferred to another country without appropriate safeguards being in place (Transfer Limitation).

(h) Made available to Data Subjects and Data Subjects allowed to exercise certain rights in relation to their Personal Data (Data Subject’s Rights and Requests).

We are responsible for and must be able to demonstrate compliance with the data protection principles listed above (Accountability).

5. Lawfulness, fairness, transparency

5.1 Lawfulness and fairness

Personal data is Processed lawfully, fairly and in a transparent manner in relation to the Data Subject.

We only collect, Process and share Personal Data fairly and lawfully and for specified purposes. The GDPR restricts our actions regarding Personal Data to specified lawful purposes. These restrictions are not intended to prevent Processing, but ensure that we Process Personal Data fairly and without adversely affecting the Data Subject.

The GDPR allows Processing for specific purposes, some of which are set out below:

(a) the Data Subject has given his or her Consent;

(b) the Processing is necessary for the performance of a contract with the Data Subject;

(c) to meet our legal compliance obligations;

(d) to protect the Data Subject’s vital interests;

(e) to pursue our legitimate interests for purposes where they are not overridden because the Processing prejudices the interests or fundamental rights and freedoms of Data Subjects. The purposes for which we process Personal Data for legitimate interests need to be set out in applicable Privacy Notices; or

5.2 Consent

A Controller will only process Personal Data on the basis of one or more of the lawful bases set out in the GDPR, which include Consent.

A Data Subject consents to Processing of their Personal Data if they indicate agreement either by a statement or positive action to the Processing. If Consent is given in a document which deals with other matters, then the Consent must be kept separate from those other matters. All data collected and processed also includes any data or assets exchanged between Britannic Health Media Ltd in conjunction with the Asset Sale, Purchase and Transfer agreement between the following companies, documented and available upon request. Stafford & Spires Ltd, Insider Health Media Ltd, NutraGenetics Ltd, Natures Home Remedies, New Horizons Research, Novo Science, BioGenetics Europe, Nutraceutical Health Research, North Shore Health Ltd

Data Subjects can easily withdraw Consent to Processing at any time and withdrawal will be promptly honoured. Consent will need to be refreshed if we intend to Process Personal Data for a different and incompatible purpose which was not disclosed when the Data Subject first consented.

Unless we can rely on another legal basis of Processing, Explicit Consent is usually required for Processing Special Categories of Personal Data and Criminal Convictions Data, for Automated Decision-Making and for cross border data transfers. Usually we will be relying on another legal basis (and not require Explicit Consent) to Process most types of Special Categories of Personal Data and Criminal Convictions Data.

5.3 Transparency (notifying data subjects)

Whenever we collect Personal Data directly from Data Subjects, including for human resources or employment purposes, we can provide the Data Subject with all the information required by the GDPR including the identity of the Controller and DPO, how and why we will use, Process, disclose, protect and retain that Personal Data upon request through a Privacy Notice which must be presented when the Data Subject first provides the Personal Data.

When Personal Data is collected indirectly (for example, from a third party or publicly available source). We also check that the Personal Data collected by the third party in accordance with the GDPR and on a basis which contemplates our proposed Processing of that Personal Data.

6. Purpose limitation

Personal Data is only collected for specified, explicit and legitimate purposes. It is not be further Processed in any manner incompatible with those purposes.

7. Data minimisation

Personal Data must be adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed.

We only Process Personal Data when performing our job duties. We do not Process Personal Data for any reason unrelated to your job duties.

We ensure that when Personal Data is no longer needed for specified purposes, it is deleted or anonymised in accordance with the GDPR guidelines.

8. Accuracy

Personal Data must be accurate and, where necessary, kept up to date. Data is corrected or deleted without delay when inaccurate.

We ensure that the Personal Data we use and hold is accurate, complete, kept up to date and relevant to the purpose for which we collected it. You must check the accuracy of any Personal Data at the point of acceptance and at regular intervals afterwards. We take all reasonable steps to destroy or amend inaccurate or out-of-date Personal Data.

9. Storage limitation

Personal Data is not be kept in an identifiable form for longer than is necessary for the purposes for which the data is processed.

We do not keep Personal Data in a form which permits the identification of the Data Subject for longer than needed for the legitimate business purpose or purposes for which we originally collected it including for the purpose of satisfying any legal, accounting or reporting requirements.

Health Affiliates Limited will maintain retention policies and procedures to ensure Personal Data is deleted after a reasonable time for the purposes for which it was being held, unless a law requires such data to be kept for a minimum time. We take all reasonable steps to destroy or erase from our systems all Personal Data that we no longer require in accordance with all the Company’s applicable records retention schedules and policies. This includes requiring third parties to delete such data where applicable.

10. Security integrity and confidentiality

10.1 Protecting Personal Data

Personal Data must be secured by appropriate technical and organisational measures against unauthorised or unlawful Processing, and against accidental loss, destruction or damage.

We will develop, implement and maintain safeguards appropriate to our size, scope and business, our available resources, the amount of Personal Data that we own or maintain on behalf of others and identified risks (including use of encryption and Pseudonymisation where applicable). We will regularly evaluate and test the effectiveness of those safeguards to ensure security of our Processing of Personal Data. We exercise particular care in protecting Special Categories of Personal Criminal Convictions Data from loss and unauthorised access, use or disclosure.

Health Affiliates Limited only transfer Personal Data to third-party service providers who agree to comply with the required policies and procedures and who agree to put adequate measures in place, as requested.

We maintain data security by protecting the confidentiality, integrity and availability of the Personal Data, defined as follows:

(a) Confidentiality means that only people who have a need to know and are authorised to use the Personal Data can access it.

(b) Integrity means that Personal Data is accurate and suitable for the purpose for which it is processed.

(c) Availability means that authorised users are able to access the Personal Data when they need it for authorised purposes.

10.2 Reporting a Personal Data Breach

The GDPR requires Controllers to notify any Personal Data Breach to the applicable regulator and, in certain instances, the Data Subject.

We have put in place procedures to deal with any suspected Personal Data Breach and will notify Data Subjects or any applicable regulator where we are legally required to do so.

If you know or suspect that a Personal Data Breach has occurred, do not attempt to investigate the matter yourself. Immediately contact the person or team designated as the key point of contact for Personal Data Breaches on [email protected] .  All evidence and requests will be preserved relating to the potential Personal Data Breach where an investigate will be launched. Please only contact the contact above for investigation procedures to begin.

11. Transfer limitation

The GDPR restricts data transfers to countries outside the EEA in order to ensure that the level of data protection afforded to individuals by the GDPR is not undermined. You transfer Personal Data originating in one country across borders when you transmit, send, view or access that data in or to a different country.

We will only transfer Personal Data outside the EEA if one of the following conditions applies:

(a) the European Commission has issued a decision confirming that the country to which we transfer the Personal Data ensures an adequate level of protection for the Data Subjects’ rights and freedoms;

(b) appropriate safeguards are in place such as binding corporate rules (BCR), standard contractual clauses approved by the European Commission, an approved code of conduct or a certification mechanism, a copy of which can be obtained from the DPO;

(c) the Data Subject has provided Explicit Consent to the proposed transfer after being informed of any potential risks; or

(d) the transfer is necessary for one of the other reasons set out in the GDPR including the performance of a contract between us and the Data Subject, reasons of public interest, to establish, exercise or defend legal claims or to protect the vital interests of the Data Subject where the Data Subject is physically or legally incapable of giving Consent and, in some limited cases, for our legitimate interest.

12. Data Subject’s rights and requests

Data Subjects have rights when it comes to how we handle their Personal Data. These include rights to:

(a) withdraw Consent to Processing at any time;

(b) receive certain information about the Data Controller’s Processing activities;

(c) request access to their Personal Data that we hold;

(d) prevent our use of their Personal Data for direct marketing purposes;

(e) ask us to erase Personal Data if it is no longer necessary in relation to the purposes for which it was collected or Processed or to rectify inaccurate data or to complete incomplete data;

(f) restrict Processing in specific circumstances;

(g) challenge Processing which has been justified on the basis of our legitimate interests or in the public interest;

(h) request a copy of an agreement under which Personal Data is transferred outside of the EEA;

(i) object to decisions based solely on Automated Processing, including profiling (ADM);

(j) prevent Processing that is likely to cause damage or distress to the Data Subject or anyone else;

(k) be notified of a Personal Data Breach which is likely to result in high risk to their rights and freedoms;

(l) make a complaint to the supervisory authority; and

(m) in limited circumstances, receive or ask for their Personal Data to be transferred to a third party in a structured, commonly used and machine readable format.

We must verify the identity of an individual requesting data under any of the rights listed above (we do not allow third parties to request this on your behalf without proper authorisation).

13. Accountability

13.1 The Controller must implement appropriate technical and organisational measures in an effective manner, to ensure compliance with data protection principles. The Controller is responsible for, and must be able to demonstrate, compliance with the data protection principles.

The Company must have adequate resources and controls in place to ensure and to document GDPR compliance including:

(a) appointing a suitably qualified DPO (where necessary) and an executive accountable for data privacy;

(b) implementing Privacy by Design when Processing Personal Data and completing DPIAs where Processing presents a high risk to rights and freedoms of Data Subjects;

(c) integrating data protection into internal documents including this Privacy Standard, Related Policies, Privacy Guidelines or Privacy Notices;

(d) regularly training Company Personnel on the GDPR, this Privacy Standard, Related Policies and Privacy Guidelines and data protection matters including, for example, Data Subject’s rights, Consent, legal basis, DPIA and Personal Data Breaches. The Company must maintain a record of training attendance by Company Personnel; and

(e) regularly testing the privacy measures implemented and conducting periodic reviews and audits to assess compliance, including using results of testing to demonstrate compliance improvement effort.

13.2 Record keeping

The GDPR requires us to keep full and accurate records of all our data Processing activities.

We keep and maintain accurate corporate records reflecting our Processing of data.

13.3 Training and audit

We are required to ensure all Company Personnel have undergone adequate training to enable them to comply with data privacy laws. We must also regularly test our systems and processes to assess compliance.

We regularly review all the systems and processes under our control to ensure they comply with this Privacy Standard and check that adequate governance controls and resources are in place to ensure proper use and protection of Personal Data.

13.4 Privacy By Design and Data Protection Impact Assessment (DPIA)

We are required to implement Privacy by Design measures when Processing Personal Data by implementing appropriate technical and organisational measures (like Pseudonymisation) in an effective manner, to ensure compliance with data privacy principles.

We assess what Privacy by Design measures can be implemented on all programs/systems/processes that Process Personal Data by taking into account the following:

(a) the state of the art;

(b) the cost of implementation;

(c) the nature, scope, context and purposes of Processing; and

(d) the risks of varying likelihood and severity for rights and freedoms of Data Subjects posed by the Processing.

We conduct a DPIA (and discuss your findings with the DPO) when implementing major system or business change programs involving the Processing of Personal Data including:

(e) use of new technologies (programs, systems or processes), or changing technologies (programs, systems or processes);

(f) Automated Processing including profiling and ADM;

(g) large scale Processing of Special Categories of Personal Data or Criminal Convictions Data Data; and

(h) large scale, systematic monitoring of a publicly accessible area.

A DPIA must include:

(i) a description of the Processing, its purposes and the Data Controller’s legitimate interests if appropriate.

(j) an assessment of the necessity and proportionality of the Processing in relation to its purpose;

(k) an assessment of the risk to individuals; and

(l) the risk mitigation measures in place and demonstration of compliance.

13.5 Automated Processing (including profiling) and Automated Decision-Making

Generally, ADM is prohibited when a decision has a legal or similar significant effect on an individual unless:

(a) a Data Subject has consented;

(b) the Processing is authorised by law; or

(c) the Processing is necessary for the performance of or entering into a contract.

If certain types of Special Categories of Personal Data or Criminal Convictions Data are being processed, then grounds (b) or (c) will not be allowed but such Special Categories of Personal Data and Criminal Convictions Data can be Processed where it is necessary (unless less intrusive means can be used) for substantial public interest like fraud prevention.

If a decision is to be based solely on Automated Processing (including profiling), then Data Subjects must be informed when you first communicate with them of their right to object. This right must be explicitly brought to their attention and presented clearly and separately from other information. Further, suitable measures must be put in place to safeguard the Data Subject’s rights and freedoms and legitimate interests.

13.6 Direct marketing

We are subject to certain rules and privacy laws when marketing to our customers.

For example, a Data Subject’s prior consent is required for electronic direct marketing (for example, by email, text or automated calls). The limited exception for existing customers known as “soft opt in” allows organisations to send marketing texts or emails if they have obtained contact details in the course of a sale to that person, they are marketing similar products or services, and they gave the person an opportunity to opt out of marketing when first collecting the details and in every subsequent message.

A Data Subject’s objection to direct marketing is promptly honoured. If a customer opts out at any time, their details are suppressed as soon as possible. Suppression involves retaining just enough information to ensure that marketing preferences are respected in the future.

13.7 Sharing Personal Data

Generally, we are not allowed to share Personal Data with third parties unless certain safeguards and contractual arrangements have been put in place.

We only share the Personal Data we hold with third parties, such as our service providers if:

(a) they have a need to know the information for the purposes of providing the contracted services;

(b) sharing the Personal Data complies with the Privacy Notice provided to the Data Subject and, if required, the Data Subject’s Consent has been obtained;

(c) the third party has agreed to comply with the required data security standards, policies and procedures and put adequate security measures in place;

(d) the transfer complies with any applicable cross border transfer restrictions; and

(e) a fully executed written contract that contains GDPR approved third party clauses has been obtained.

14. Changes to this Privacy Standard

We reserve the right to change this Privacy Standard at any time so please check back regularly to obtain the latest copy of this Privacy Standard. We last revised this Privacy Standard on 1st June 2019

This Privacy Standard does not override any applicable national data privacy laws and regulations in countries where the Company operates