Why do we collect the information?
We collect your personal information so we can identify you and interact with you for the purposes described herein
Our legal basis for processing your personal information
When we use your personal information we are required to have a legal basis for doing so. There are various different legal bases on which we may rely, depending on what personal information we process and why.
The legal bases we may rely on include:
- consent: where you have given us clear consent for us to process your personal information for a specific purpose
- contract: where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract
- legal obligation: where our use of your personal information is necessary for us to comply with the law (not including contractual obligations)
- legitimate interests: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information which overrides our legitimate interests)
Sensitive personal information
We may also collect health information from you when reporting an adverse reaction to a product. This information must be collected in order to provide you with a suitable products and services and for our health and safety reporting obligations. We will not process this sensitive personal information without your explicit consent (unless required by any applicable law) and we will not process sensitive personal information by way of any automated process.
Do you have to identify yourself when you interact with Citizen Spritz?
If you wish to remain anonymous when you use the Citizen Spritz website, do not sign in to the website or provide any information which may identify you. Please note however that we are unable to perform a number of our functions without obtaining your identifying information. For example, we may require details about your identity if you register or log into our website, contact us with an enquiry or complaint, request to receive communications from us, participate in our promotions or competitions, require us to deliver products to you and, in some cases, process a payment.
How can you request not to receive direct marketing?
If you do not wish to receive direct marketing communications from us please follow the ‘opt-out’ or ‘unsubscribe’ instruction in that communication or on our website, or otherwise email us at [email protected] and provide your name, e-mail address and postal address and information about the direct marketing communication you no longer wish to receive.
Who do we disclose your personal information to?
We may disclose your personal information:
- To third parties who store or process it on our behalf in order to assist us in providing, promoting and marketing as well as developing and improving our products and services. Companies include;
- Facebook Messenger chat bot (messenger chat service)
- We may combine personal information we receive about you with other information we hold about you. This includes information received from third parties and publicly available information;
- where required by law, or to government and enforcement agencies or individuals appointed by a government responsible for investigating and resolving disputes or complaints concerning Citizen Spritz products or where such disclosure is necessary to protect the safety or security of persons;
- as otherwise permitted under applicable laws.
We will not disclose any health information to third parties or use it for any purpose other than as set forth herein.
Do we transfer, process or disclose your personal information overseas?
We may disclose your personal information to third party service providers who provide services to Citizen Spritz including data warehousing, credit card processing and e-commerce services, mailing and logistics services. By disclosing personal information to us, you acknowledge and consent to these potential transfers.
How do we hold your personal information and keep it secure?
We hold your personal information in a combination of electronic and hard copy files. We may store your personal information with third party data storage providers.
We take all reasonable steps to ensure that the personal information we hold is protected from misuse, interference and loss, and unauthorised access, modification or disclosure by the use of various methods, including secure physical and technological storage. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so. Where we provide your personal information to third party service providers, we require them to keep it secure in accordance with relevant data privacy laws and only use or disclose it for the purpose for which it was provided.
Please contact us immediately if you become aware or have reason to believe there has been any unauthorised use of your personal information that we hold.
Your rights and who to contact
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
- fair processing of information and transparency over how we use your use personal information
- access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
- require us to correct any mistakes in your information which we hold
- require the erasure of personal information concerning you in certain situations
- receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
- object at any time to processing of personal information concerning you for direct marketing
- object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
- object in certain other situations to our continued processing of your personal information
- otherwise restrict our processing of your personal information in certain circumstances
- claim compensation for damages caused by our breach of any data protection laws
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
Please contact us via one of the following if you would like to exercise any of the above rights:
- Mail: Citizen Spritz, Innovation House, Unit B, Abex Rd, Newbury, RG14 5EY, United Kingdom
- email: [email protected]
We will ask that you put your request for access in writing and provide us with proof of your identity.
How can you access further information or complain about a breach of your privacy?
We will investigate any complaint, and notify you of our decision in relation to the complaint, as soon as practicable after it is received. If we are unable to satisfactorily resolve your concerns about our handling of your personal information, you can contact the ICO at the following: https://ico.org.uk/concerns/ or telephone: 0303 123 1113.