We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).
It would be helpful to start by explaining some key terms used in this policy:
|We, us, our
|Sleeping Bunnies Ltd and our group companies
|Any information relating to an identified or identifiable individual
|Special category personal data
|Personal data revealing racial or ethnic origin, religious beliefs, philosophical beliefs Data concerning health
|The individual who the personal data relates to
The personal data we collect about you depends on the particular services we provide to you. We will collect and use the following personal data about you:
- your name and contact information, including email address and telephone number
- information to check and verify your identity, eg your date of birth
- your gender, if you choose to give this to us
- location data, if you choose to give this to us
- your billing information, transaction and payment card information
- Information about how you use our website, IT, communication and other systems
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you.
We collect most of this personal data directly from you—in person, by telephone, text or email and/or via our website. However, we may also collect information:
- via our IT systems, e.g. through automated monitoring of our websites and other technical systems, such as our computer networks and connections, communications systems, email and instant messaging systems.
Under data protection law, we can only use your personal data if we have a proper reason, eg:
- where you have given consent;
- to comply with our legal and regulatory obligations;
- for the performance of a contract with you or to take steps at your request before entering into a contract; or
- for our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.
The table below explains what we use your personal data for and why.
|What we use your personal data for
|Providing services to you
|To perform our contract with you or to take steps at your request before entering into a contract
|Preventing and detecting fraud against you or us
|For our legitimate interest, ie to minimise fraud that could be damaging for you and/or us
|Conducting checks to identify our customers and verify their identity Screening for financial and other sanctions or embargoes Other activities necessary to comply with legal and regulatory obligations that apply to our business, eg under health and safety law
|Depending on the circumstances: —to comply with our legal and regulatory obligations —for our legitimate interests
|To enforce legal rights or defend or undertake legal proceedings
|Depending on the circumstances: —to comply with our legal and regulatory obligations; —in other cases, for our legitimate interests, ie to protect our business, interests and rights
|Ensuring business policies are adhered to, eg policies covering security and internet use
|For our legitimate interests, ie to make sure we are following our own internal procedures so we can deliver the best service to you
|Operational reasons, such as improving efficiency, training and quality control
|For our legitimate interests , ie to be as efficient as we can so we can deliver the best service to you at the best price
|Ensuring the confidentiality of commercially sensitive information
|Depending on the circumstances: —for our legitimate interests, ie to protect trade secrets and other commercially valuable information; —to comply with our legal and regulatory obligations
|Statistical analysis to help us manage our business, eg in relation to insert, eg our financial performance, customer base, or other efficiency measures
|For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price
|Preventing unauthorised access and modifications to systems
|Depending on the circumstances: —for our legitimate interests, ie to prevent and detect criminal activity that could be damaging for you and/or us; —to comply with our legal and regulatory obligations
|Protecting the security of systems and data used to provide the services
|To comply with our legal and regulatory obligations We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us
|Updating and enhancing customer records
|Depending on the circumstances: —to perform our contract with you or to take steps at your request before entering into a contract; —to comply with our legal and regulatory obligations; —for our legitimate interests, eg making sure that we can keep in touch with our customers about existing orders and new products
|To comply with our legal and regulatory obligations
|Ensuring safe working practices, staff administration and assessments
|Depending on the circumstances: —to comply with our legal and regulatory obligations; —for our legitimate interests, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
|Marketing our services to: —existing and former customers; —third parties who have previously expressed an interest in our services; —third parties with whom we have had no previous dealings.
|For our legitimate interests, ie to promote our business to existing and former customers
|External audits and quality checks
|Depending on the circumstances: —for our legitimate interests, ie to maintain our accreditations so we can demonstrate we operate at the highest standards; —to comply with our legal and regulatory obligations
|To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency In such cases information will be anonymised where possible and only shared where necessary
|Depending on the circumstances: —to comply with our legal and regulatory obligations; —in other cases, for our legitimate interests, ie to protect, realise or grow the value in our business and assets
How and why we use your personal data—in more detail
More details about how we use your personal data and why are set out in the table below.
|Lawful basis relied on under the UK GDPR
|Relevant categories of personal data
|Communications with you not related to marketing, including about changes to our terms or policies or changes to the products or other important notices (other than those addressed above)
|Addressing and sending communications to you as required by data protection laws, ie: —the UK GDPR or Data Protection Act 2018;
|Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b))
|—your name, address and contact information, including email address and telephone number —your account details (username)
|Addressing and sending communications to you about changes to our terms or policies or changes to the products or other important notices
|Our legitimate interests (Article 6(1)(f)), which is to be as efficient as we can so we can deliver the best service to you
|—your name, address and contact information, including email address and telephone number —your account details (username)
How and why we use your personal data—Special category personal data
Certain personal data we collect is treated as a special category to which additional protections apply under data protection law:
- personal data revealing racial or ethnic origin, religious beliefs, philosophical beliefs; and
- data concerning health.
Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws, eg:
- we have your explicit consent;
- the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or
- the processing is necessary to establish, exercise or defend legal claims.
How and why we use your personal data—sharing
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
We will use your personal data to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by contacting us.
We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never share it with other organisations outside of our group for marketing purposes.
We routinely share personal data with:
- companies within our group
- third parties we use to help deliver our services to you, eg payment service providers, warehouses and delivery companies;
- other third parties we use to help us run our business, eg marketing agencies or website hosts;
- third parties approved by you, eg social media sites you choose to link your account to or third party payment providers;
- our insurers and brokers;
- our banks.
We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.
We or the third parties mentioned above occasionally also share personal data with:
- our and their external auditors, eg in relation to the audit of our or their accounts, in which case the recipient of the information will be bound by confidentiality obligations;
- our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
- law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations;
- other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.
Who we share your personal data with—in more detail
More details about who we share your personal data with and why are set out in the table below.
|Processing operation (use) by recipient
|Relevant categories of personal data transferred to recipient
|Microsoft Corporation, a company registered in the US state of Washington (company number 600413485) and whose registered office is One, Microsoft Way, Redmond, Washington 98052-6399, United States / Microsoft Limited, a company registered in England and Wales (company number 01624297) and whose registered office is Microsoft Campus, Thames Valley Park, Reading, Berkshire, RG6 1WG
|Names and addresses, and other personal data you might provide us by email
|WhatsApp LLC, a company registered in the US state of Delaware (company file number 5482270) and whose registered office is 1601 Willow Road Menlo Park, California 94025, United States
|Names and addresses, and other personal data you might provide us by message
Who we share your personal data with—further information
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
Personal data may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).
Some of these third parties may be based outside the UK. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK’.
We will not keep your personal data for longer than we need it for the purpose for which it is used.
If you no longer have an account with us or we are no longer providing services to you, we will delete or anonymise your account data after seven years.
Countries outside the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.
It is sometimes necessary for us to transfer your personal data to countries outside the UK. In those cases we will comply with applicable UKlaws designed to ensure the privacy of your personal data.
Under data protection laws, we can only transfer your personal data to a country outside the UK where:
- in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available here.
- there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or
- a specific exception applies under relevant data protection law.
Where we transfer your personal data outside the UK, we do so on the basis of an adequacy regulation or (where this is not available) legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time, we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.
Transferring your personal data out of the UK—further information
If you would like further information about data transferred outside the UK, please contact us (see ‘How to contact us’ below).
You have the following rights, which you can exercise free of charge:
|The right to be provided with a copy of your personal data
|The right to require us to correct any mistakes in your personal data
|Erasure (also known as the right to be forgotten)
|The right to require us to delete your personal data—in certain situations
|Restriction of processing
|The right to require us to restrict processing of your personal data in certain circumstances, eg if you contest the accuracy of the data
|The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
|The right to object: —at any time to your personal data being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims
|Not to be subject to automated individual decision making
|The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
|The right to withdraw consents
|If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time You may withdraw consents by contacting us Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn
For more information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.
If you would like to exercise any of those rights, please:
- email, call or write to us—see below: ‘How to contact us’; and
- provide enough information to identify yourself (eg your full name, address and order reference number) and any additional identity information we may reasonably request from you;
- let us know what right you want to exercise and the information to which your request relates.
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your personal data and other information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner.
The Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
Individuals in the UK
Our contact details are shown below:
07821 851941 (our telephone lines are open Monday to Friday: 9 am to 5 pm, excluding bank or public holidays in England)
If you would like this notice in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).