1. Introduction 
2. Explaining the legal bases, we rely on 
3. When do we collect your personal data? 
4. What sort of personal data do we collect? 
5. How and why do we use your personal data? 
6. Combining your data for personalised direct marketing 
7. How we protect your personal data 
8. How long will we keep your personal data? 
9. Who do we share your personal data with? 
10. Where your personal data may be processed 
11. What are your rights over your personal data? 
12. How can you stop the use of your personal data for direct marketing? 

1. Introduction

• This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we store and handle that data and keep it safe. 
• We hope the following sections will answer any questions you have but if not, please do get in touch with us. 
• It is likely that we will need to update this Privacy Notice from time to time. We will notify you of any significant changes, but you are welcome to come back and check it whenever you wish. 

2. Explaining the legal bases we rely on

• The Law on Data Protection sets out several different reasons for which a company may collect and process your personal data, including: 

Consent

• In specific situations, we can collect and process your data with your consent.  

• When collecting your personal data, we will always make clear to you which data is necessary in connection with a particular service. 

Contractual obligations 

• In certain circumstances, we need your personal data to comply with our contractual obligations.  

Example – if you order an item from us for home delivery, we will collect your address and contact details to deliver your purchase and pass them to our courier.  

Legal compliance 

• If the law requires us to, we may need to collect and process your data. 

Example – we can pass on details of people involved in fraud or any other criminal activity affecting the business, to law enforcement. 

Legitimate interest 

• In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom, or interests.  

Example – we may use your purchase history to send you or make available personalised offers 

• We also combine the shopping history of many customers to identify trends and ensure we can keep up with demand, and develop new products/services 

• We may also use your address details to send you direct marketing information by post, advising you about products and services that we think might interest you. 

3. When do we collect your personal data?

• When you visit our website, and use your account to buy products and services, or on the phone, or in person at our retail shop(s). 
• When you make an online purchase and check out as a guest (in which case we just collect transaction-based data). 
• When you create an account with us. 
• When you purchase a product or service in store or by phone but do not have (or don’t use) an account. 
• When you engage with us on social media. 
• When you contact us by any means with queries, complaints etc. 
• When you ask one of our staff to email you information about a product or service. 
• When you enter prize draws or competitions. 
• When you choose to complete any surveys, we send you.
• When you comment on or review our products and services. 
• Any individual may access personal data related to them, including opinions. So, if your comment or review includes information about the team member who provided that service, it may be passed on to them if requested. 
• When you fill in any forms. For example, if an accident happens in store, or a delivery issue, a team member may collect your personal data. 
• When you’ve given a third-party permission to share with us the information, they hold about you. 
• We collect data from publicly available sources when you have given your consent to share information or where the information is made public as a matter of law. 
• When you visit our premises which usually have CCTV systems operated for the security of both customers and staff. These systems may record your image during your visit. 

4. What sort of personal data do we collect?

• If you have a web account with us: your name, billing/delivery address, orders and receipts, email, and telephone number
• Details of your interactions with us through our contact centre, in store, or online. 
  Example – we collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made, items viewed or added to your basket, voucher redemptions, products you show interest in, web pages you visit and how and when you contact us. 
• Details of your shopping preferences.  

• Details of your visits to our website, and which site you came from to ours. 
• Information gathered using cookies in your web browser. Learn more about how we use cookies  
• Personal details which help us to recommend items of interest. 

• We will only ask for and use your personal data collected for recommending products of interest and to tailor your shopping experience with us. Of course, it is always your choice whether you share such details with us 
• Your comments and product reviews 
• Your image may be recorded on CCTV when you visit our premises 
• Your car number plate may be recorded at some of our car parks to manage parking restrictions. 
• To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered. Cookie Policy
• Your social media username, if you interact with us through those channels, to help us respond to your comments, questions, or feedback. 

5. How and why do we use your personal data?

• We want to give you the best possible customer experience.  To achieve this, we need to understand your requirements and to obtain the best picture we can of who you are by combining the data we hold.
• We use this information to offer you promotions, products and services that are most likely to interest you. 
• In the case of loyalty scheme members, we may also offer you relevant rewards. 
• The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service. 
• If you wish to change how we use your data, you will find details in the ‘What are my rights?’ section below. 
• Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you have requested. 

Example – if you have asked us to let you know when an item comes back into stock, we cannot do that if you have withdrawn your general consent to hear from us. 

This is how we will use your personal data and why: – 

• To process any orders that you make by using our website, via the telephone, via apps or in store. If we do not collect your personal data during checkout, we will not be able to process your order and comply with our legal obligations.  

Example – your details may need to be passed to a third party to supply or deliver the product or service that you ordered, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds and so on. 

• To respond to your queries, refund requests and complaints. Handling the information, you send to us enables us to respond to any future communication with us and to demonstrate how we communicated with you throughout. We do this based on our contractual obligations to you, our legal obligations, and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience 
• To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We will also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We will do all of this as part of our legitimate interest.  

Example – by checking your password when you login and using automated monitoring of IP addresses to identify possible fraudulent logins from unexpected locations. 

• To protect our customers, premises, assets, and staff from crime, we operate CCTV systems on our premises which record images for security. We do this based on our legitimate business interests. 
• To process payments and to prevent fraudulent transactions. We do this based on our legitimate business interests. This also helps to protect our customers from fraud. 
• If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts.  Our aim is to protect the individuals we interact with from criminal activities. 
• With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, our website, text, telephone and through our contact centres about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on. 
• You are free to opt out of hearing from us by any of these channels at any time. 
• To send you relevant, personalised communications by post in relation to updates, offers, services and products. We will do this based on our legitimate business interest.  You are free to opt out of hearing from us by post at any time. 
• To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, product recall notices, and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations. 
• To display the most interesting content to you on our website or apps, we will use data we hold about your favourite products. We do so based on your consent to receive app notifications and/or for our website to place cookies or similar technology on your device. 

Example – we might display a list of items you have recently looked at or offer you recommendations based on your purchase history and any other data you have shared with us. 

• To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering. 
• To develop, test and improve the systems, services, and products we provide to you. We’ll do this on the basis of our legitimate business interests. 

Example – we will record your browser’s Session ID to help us understand more when you leave us online feedback about any problems, you’re having 

• To comply with our contractual or legal obligations to share data with law enforcement. 
• To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you. 
• You are free to opt out of receiving these requests from us at any time by updating your preferences in your online account. 

6. Combining your data for personalised direct marketing

• We want to bring you offers and promotions that are most relevant to your interests at particular times. To help us form a better, overall understanding of you as a customer, we combine your personal data gathered across the business as described above, for example your shopping history at Natural Instinct Limited. For this purpose, we also combine the data that we collect directly from you with data that we obtain from third parties to whom you have given your consent to pass that data onto us.

7. How we protect your personal data

• We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it. 
• We secure access to all transactional areas of our websites using ‘https’ technology. 
• Access to your personal data is password-protected, and sensitive data (such as payment card information) is secured by SSL encryption with redirection methods to the payment gateway. 
• We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security. 

8. How long will we keep your personal data?

• Whenever we collect or process your personal data, we will only keep it for as long as is necessary for the purpose for which it was collected.  
• At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning. 
• When you place an order, we’ll keep the personal data you give us for seven years so we can comply with our legal and contractual obligations. 

9. Who do we share your personal data with?

• We sometimes share your personal data with trusted third parties.  

Example – delivery couriers, for fraud management, to handle complaints, to help us personalise our offers to you and so on.  

• Here is the policy we apply to those organisations to keep your data safe and protect your privacy: 
  • We provide only the information they need to perform their specific services. 
  • They may only use your data for the exact purposes we specify in our contract with them. 
  • We work closely with them to ensure that your privacy is always respected and protected. 
  • If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.  

• Examples of the kind of third parties we work with are: 
  • IT companies who support our website and other business systems. 
  • Operational companies such as delivery couriers. 
  • Direct marketing companies who help us manage our electronic communications with you. 
  • Google / Facebook / Twitter to show you products that might interest you while you are browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our websites. 
  • Data insight companies to ensure your details are up to date and accurate.

• Sharing your data with third parties for their own purposes: 

We will only do this in very specific circumstances

Example – with your consent, given at the time you supply your personal data, we may pass that data to a third party for their direct marketing purposes – if you enter a dog grooming competition and tick a box agreeing that the dog grooming company can send you promotional information directly. Or if we run a joint event with your local stockist, and you agree to receive direct communications from them. 

Example – for fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies. 

Example – We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration. 

Example – We may, from time to time, expand, reduce, or sell Circle of Life Food and this may involve the transfer of divisions or the whole business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owner or controlling party, under the terms of this Privacy Notice. 

For further information please contact our Privacy Manager. 

10. Where your personal data may be processed

International transfers of personal data, and the measures in place to safeguard it 

We do not directly transfer any of your personal data outside the European Economic Area (EEA). However, some of our data processors may do so and this section explains the impact of these international transfers and how your information is protected.

Many of our data processors operate “cloud-based systems”, which means the information is held in information data centres in different locations. All the cloud-based systems we use reserve the right to hold copies of your personal information outside the EEA to hold back-up copies, so they can guarantee recovery.

In each case we and/or our processors use one or more of the following means that are designed to help safeguard your privacy rights and give you remedies in the unlikely event of abuse:

• Certain processors may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries. 
• Where personal data is transferred outside the EEA or countries the EC deems to have adequate privacy protection, we use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries. 
• Providers storing data in the US may be self-certified to the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield. 

11. What are your rights over your personal data?

An overview of your different rights 

You have the right to request: 

• Access to the personal data we hold about you, free of charge in most cases. 
• The correction of your personal data when incorrect, out of date or incomplete. 
• For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end. 
• That we stop using your personal data for direct marketing (either through specific channels, or all channels). 
• That we stop any consent-based processing of your personal data after you withdraw that consent. 
• Review by a Partner of any decision made based solely on automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision). 
• If we choose not to action your request, we will explain to you the reasons for our refusal. 
• Your right to withdraw consent – whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent. 
• Where we rely on our legitimate interest – in cases where we are processing your personal data based on our legitimate interest, you can ask us to stop for reasons connected to your individual situation.  We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data. 
• Direct marketing – you have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request. 
• Checking your identity – to protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act. 

12. How can you stop the use of your personal data for direct marketing?

There are several ways you can stop direct marketing communications from us: 

• Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails from our marketing department. 
• If you have an account, log in into your Circle of Life Food, visit the ‘My Account’ area and change your preferences. 
• Write to the Circle of Life Food, 8 Westerham avenue, London N9 9BU. Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.