Privacy Policy

It is important that you take some time to read and familiarise yourself with this Notice, together with our website terms and conditions and any other privacy or fair processing notices that we may provide on specific occasions when we are collecting or processing personal data about you. This will help you to be fully aware of how and why we are using your information.

If you do not agree with any term in this policy, please do not use the website or submit any personal information to or through it.

Controller

NaeBother Ltd (registered company number SC625790) is the data controller responsible for your personal data.

Our registered address is:

NaeBother Ltd

c/o Henry Brown & Co

26 Portland Road

Kilmarnock,

Ayrshire KA1 2EB

All references to “our”, “us”, “we” or “Company” within this policy are deemed to refer to NaeBother Ltd

Contact Details

Our contact details are the same as above

Changes to this Privacy Policy

This Privacy Policy was last updated in November 2019; however we keep this policy under review. We will show any updates to it on this webpage. We recommend that you check this page regularly to ensure that you have read the most recent version. Please note, it is important that the personal data we hold about you is accurate and current. Please keep us informed if personal data we hold about you changes during your relationship with us.

Third party links

From time to time this website may include links to third-party websites, plug-ins, platforms 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 or for how they collect and use your personal information. When you leave our website, we strongly advise you to read the privacy notice of every website you visit before you submit any personal information to them.

Information we may collect from you

Data collection and storage You can visit our website without telling us who you are or providing any personal data. We will only save the following access data without any personally identifying information, even if you are coming to our website from a newsletter or social link:

• The name of your internet service provider (ISP)
• The website you are coming to us from
• The name of the requested file

This data is used solely for the purpose of improving our services and cannot be traced back to you.

We collect, store, and process your data in order to complete your purchase order and handle any subsequent guarantee claims, as well as for promotional purposes. We collect and process the following personal data about you when you visit our website, or if you voluntarily provide us with it when ordering or registering for our newsletter:

• Your contact information including your email address
• Your account details from the ordering process
• Online identifiers

What are online identifiers?

When you visit a website, your browser sends information about your browser type and version, your operating system, your referrer URL, your IP address, the file name, your access status, the amount of transferred data, the date and time of the server request. This information is pseudonymised and doesn’t personally identify you.

Why do we collect data?

We process your data for the following purposes:

• Contacting you
• Promotional purposes
• Quality assurance
• Our statistics
• Processing your sales contract
• Sending our newsletter

Legal basis

We process your data in accordance with the following legal basis:

• With your consent (article 6, paragraph 1, lit. a) GDPR)
• To execute a sales contract with you (article 6, paragraph 1 lit. b) GDPR)
• When a legitimate interest on our part applies (article 6, paragraph 1, lit. f) GDPR), namely for the improvement of our service, the protection against misuse, and for our statistics

Sharing your personal data

We may disclose your personal information to our suppliers, distributors (wholly or partly owned) and other contractors who are engaged by us to assist in the provision of products and services to you, including delivery of products ordered by you and the conduct of market research which you have agreed to participate in, as well as to other third parties if:

• the third party has been appointed to perform certain functions on our behalf, (for example, to provide technical services in relation to this website and it needs access to your personal information to be able to properly perform their function;
• we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation;
• or to protect the rights, property, or safety of the company, our customers, or consumers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
• we become involved in any merger or acquisition or other transaction involving the sale of all or part of our assets, user information (including the personal information collected from you through your use of this website) may be included in the assets which are transferred to the new owner.

We use only carefully selected third parties to help us deliver our services and products to you and they are only allowed to use your personal information to deliver the services or products you have purchased, registered for or subscribed to. We do not allow them to use your personal data for their own purposes. We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

If you make a purchase we forward your personal data to contracted service providers that we use to complete your order (e.g. shipping partners or payment service providers). If you have signed up for the newsletter, the personal data that you provided upon registration will be used to send you personalised newsletters. No data will be shared with third parties.

Our privacy policies are in accordance with The Data Protection Act 2018, UK

Data sources

The data we receive comes from you (including data about the devices you are using).

Duration of storage

We will store your data:

• If you have consented to the processing of your data, until you withdraw this consent, otherwise after 6 months, or, depending on the specific type of data, in accordance with the relevant storage period prescribed by law.
• If we need the data to implement a contract, at most for as long as the contractual relationship with you is in effect, or for as long as legal retention periods are applicable. If we use your data on the basis of our legitimate interests, at most so long as it does not outweigh your interest to have this data deleted or anonymised.

How do we store your personal information?

We will take all steps reasonably necessary to ensure the security of the personal information we collect and store about you. We will use all reasonable endeavours to protect your personal information from unauthorised disclosure and / or access, however unfortunately, the transmission of information via the internet is not completely secure and we have no control over the privacy of any communication while it is in transit to us. Although we will do our best to protect your personal information, we cannot guarantee the security of your information while it is being transmitted to our site. Accordingly, any transmission is at your own risk. All information you provide to us is stored in secure managed servers and we will limit access to your personal data to those of our employees, agents, contractors and other third parties who have a business need to know. All information sent to us via forms is encrypted using SSL technology making the data unreadable for any person or robot trying to intercept it until it reaches the intended recipient (us).

Where we are legally required to do so, we will notify you and any applicable data protection authority or other regulator should there be an actual or suspected personal data breach involving your personal information.

Legitimate interests

When processing your data, we pursue the following legitimate interests:

• The improvement of our service
• The protection against misuse
• Statistics

Recipients or categories of recipients of personalised data

When processing your data, we work with the following service providers who have access to your data:

• Shipping partners
• Web hosting providers
• Ecommerce partners
• Providers of social media platforms
• Advertising networks (for ads)
• Providers of web analysis tools such as Google

Your rights as an affected party

According to article 15 ff. of the GDPR, you have—partly subject to certain conditions—the right to:

• Request information on the processing of your data
• Amend your data
• Delete or disable your data
• Limit your data
• Object to the processing of your data
• Receive your data in a transferable format and forward this to a third party
• Withdraw your consent to the processing of your data for the future
• File a complaint with the responsible oversight authority about prohibited use of your data.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. If you wish to exercise any of the rights set out above, or you have any concerns about how we process your information, please shirley@naebother.com so that we can investigate and hopefully resolve your concerns. If we are unable to satisfactorily deal with your concerns then you have the right to lodge a complaint with the appropriate data protection authority.

How to unsubscribe or withdraw consent

Where we have collected your personal information based on your consent and we have no other lawful basis on which to continue processing your information, if you subsequently withdraw your consent we will delete your personal information. You can withdraw your consent, change your preferences, or opt out from hearing further from us by letting us know using the contact details set out at section 2 of this Notice or by emailing us.

Requirement or obligation relating to the provision of data

Unless otherwise specified when collecting the data, the provision of data is neither necessary nor compulsory.

Email newsletter

By subscribing to our free newsletter you will be the first to learn about new products, valuable tips and news, as well as exclusive offers. After signing up you will receive a confirmation email with an activation link to begin receiving the newsletter. If you no longer wish to receive our newsletter you can unsubscribe at any time, simply by clicking the “unsubscribe” link in the footer of any of our newsletters or by sending an email to shirley@naebother.com

Order and contract

We save the contract text and send you an email immediately after receiving your order with your order data. You can view our terms and conditions here at any time. You can use various payment methods on our shop. Your credit card or account details are collected and processed directly by the respective payment service provider and are not saved by us. We have absolutely no access to your payment information. For specific information, refer to the respective privacy policy of your payment provider.

Anti-spam policy

NaeBother does not tolerate any spam. That does not mean, however, that we can prevent spam on the internet. If you think that you have received an unsolicited email from us, please contact shirley@naebother.com so that we can investigate the issue.

Cookies

This website uses cookies. A cookie is a small text file with an identification number which, when using our website, is transferred and recorded on your computer, together with the other, requested data. Storing these cookies helps us to tailor our website accordingly to you and makes it easier to use, for example by saving certain information you enter so that you don’t have to constantly re-type it. The file is kept ready for later access and serves to authenticate the user. As cookies are just simple files and not executable programs, they pose no danger to your computer. Depending on the chosen preferences in your internet browser, it may automatically accept cookies. This preference can be changed, and the storage of cookies completely disabled or deactivated in such a way that the user is notified as soon as a cookie is saved. In the case of a complete disabling of cookies, however, certain functions of the website will no longer be available or only in a limited form.

What cookies do we use?

Below is a table listing each cookie that may be sent to your device and what we use each cookie for. You can set your browser to reject cookies (see below for more information on how to do this.) To support our website(s) we may occasionally embed photos and video content from other third party websites such as Vimeo or YouTube. Pages with this embedded content may present you with cookies from these websites. We do not control the distribution of these cookies and you should check the relevant third party website for more information about these.

How do I control cookies?

You may refuse to accept cookies from us by configuring your browser settings. Each web browser is different so check the ‘Help’ function of your particular browser to determine how to update your particular cookie settings. The website http://www.allaboutcookies.org contains step-by-step guides which can assist you in adjusting your browser settings. To opt out of being tracked by Google Analytics across all websites visit tools.google.com/dlpage/gaoptout. Please note that switching off cookies may reduce the functionality of (or prevent access to) certain websites.

Further information on data protection

The easiest way to get in touch with us quickly is by contacting us via email at: shirley@naebother.com

Issue Date: November 2019