Privacy Notice

This notice provides you with details of tomaszdyl PR Ltd t/a GottaBe! policy for collecting and processing your personal data collected through this website.

The Data Controller for this website is tomaszdyl PR Ltd t/a GottaBe! (referred to as ‘we’, ‘us’, or ‘the Company’ in this document). If you wish to view the information we store about you, have it corrected, or request for it to be deleted please contact the Senior Management Team at hello@gottabemarketing.co.uk

Our postal and telephone contact details are given on the contact page of this website.

What information do we collect about you?

We collect the following types of personal data in order to operate our business. Personal data is any data which could be used to identify an individual person. It does not include anonymised data, or data which relates solely to a corporate entity.

We may collect and process the following personal data:

• Identity data may include first name, last name, username, date of birth, title and gender
• Contact data may include contact address, billing address, delivery address, email address, phone number(s)
• Financial data may include bank account details. We do not store debit or credit card details on this website or on any systems within our company. We may transfer you to a Paypal or Stripe payment gateway in which case they will process your data in line with policies which may be viewed on their websites https://www.paypal.com and https://stripe.com/gb
• Transaction data may include details of payments and transactions between us
• Technical data may include your IP address, login information, browser type and device type, operating system and platform, time zone setting and location. We do not correlate this data to any identifiable individual.
• Profile data may include username and encrypted password, purchases and orders, your account preferences and interests, review feedback and survey responses.
• Usage data may include information about how you use our website, such as which pages you have visited, when and for how long. We do not correlate this data to any identifiable individual.
• Marketing and communications data may include your preferences as to how you would like to be contacted by us.

We make use of aggregated data collection through services such as Google Analytics for website traffic but we never use such data to identify individuals and regard it as anonymised for the purposes of this policy.

We do not collect any Sensitive Data about you such as 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 or information about criminal convictions and offences.

If we operate any service which is targeted at a sexual minority, that service is equally available to all and not just to that minority, and any use by you of that service is not regarded as inferring that you are a member of that sexual minority.

Where you have established a contract with us e.g. for the supply of goods or services, or where we are obliged by law to process certain data about you, we will only be able to deliver the contract if you provide us with the necessary personal data. If you don’t provide us with that data, we will not be able to fulfil the contract. We will endeavour to immediately inform you that we are not able to fulfil the contract for this reason, provided that we have contact data for you.

How we collect your personal data

We collect personal data by a number of methods:

• direct contact via email, phone, post, or contact form on this website
• ordering a product or service
• signing up to any membership area on this website
• signing up for any newsletter
• requesting resources or quotations to be sent to you
• automated technologies such as Google Analytics. Such data will normally be treated as anonymous
• cookies to maintain logged in user sessions (please see our cookie policy)
• webserver logs – server logs will store IP addresses but we never relate these to any individual
• public domain resources such as your own website, Companies House, or public directories
• data provided to us by referrers such as fellow members of networking groups or business associates. Such data will only be used for the purpose for which you provided it to the referrer
• If you fail to provide personal data
• Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How do we use your data?

We will only process your personal data legally and fairly. We may use it for the following purposes:

1. to perform a contract between us for the delivery of goods or services
2. where it is in your legitimate interest and/or our legitimate interest to process your data, such as replying to a question which you have submitted via our contact form or an email link on this website
3. where there is a legal requirement for us to comply with a statutory obligation such as taxation or employment law
4. where you have consented to receive marketing material by signing up for a newsletter

Generally we do not rely on consent as a legal basis for processing your personal data unless

we are contacting you solely for marketing purposes then we rely on your consent to send you marketing material.  You may withdraw your consent at any time by emailing us at hello@gottabemarketing.co.uk or by using the unsubscribe link on any newsletter which we send to you.

If you withdraw your consent for receiving marketing communication this will not apply to any personal data stored in the course of fulfilling any contract with you, which will be retained in order to comply with taxation law.

We will only use your personal data for the purpose for which we collected it, unless we have subsequently obtained your consent to use it for a different purpose, or need to do so in our own legitimate interest such as debt collection.

We have a Data Protection Policy in place to oversee the effective and secure processing of your personal data.

Purposes for which we will use your personal data

We have set out below 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.

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.

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
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (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: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (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 (b) Contact (c) Profile (d) Usage (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 (b) Contact (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 (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) 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 (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)

Who will we share your data with?

We do not share your data with third parties for their use, unless obliged to do so for legal reasons. Your data may be processed on our behalf by our subcontracted Data Processors such as  accountants, payroll bureaus, debt collection agencies, website hosting providers, working on our behalf, and other subcontractors acting on our behalf. These subcontractors will only process your data in line with our instructions.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages 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 product/service purchase, warranty registration, product/service experience or other transactions.

 Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see COOKIE POLICY.

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.

International transfers

We do not transfer your personal data outside the UK.

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.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

By law we 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 will 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.

Your legal rights

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. 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 also have the right to 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. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

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 of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• 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.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that 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.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.Glossary

Lawful Basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Accessing and correcting your information

You have the right to request a copy of the information that we hold about you. If you would like a copy of your personal information held by us, please email hello@gottabemarketing.co.uk or write to us at GottaBe! 11 College Place Southampton SO15 2FE.

We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate.

What are your rights

If at any point you believe the information we process on you is incorrect you can request to see this information and have it corrected or deleted. If you wish to raise a complaint on how we have handled your personal data, please contact us at the above address so that we can investigate.

If you are not satisfied with our response you can complain to the Information Commissioner’s Office https://ico.org.uk/ . However we would appreciate it if you can first contact us to express your dissatisfaction so that we can attempt to resolve your concerns.

Policy updated 26/06/2023