At Organix we are committed to helping you choose the right healthy, organic food for your children. We know that food choices can be confusing, particularly for new parents, and we strive to help you make sense of your options.
We are also just as committed to protecting and respecting your privacy and your data.
In order for Organix to provide you with information that is relevant to the age and stage of your child’s development we obviously need to ask you to share some personal information with us about you and your child. This document is our Privacy Policy. It explains, amongst other things, why we ask you for some personal data, how we collect data from you when you visit our website, what we do with it, how long we keep it and your rights in relation to the data you have provided to us. We will provide details of how you can unsubscribe from Organix communications or ask for your data to be deleted.
In this document we explain our privacy policy in plain English. We have tried to avoid using legal language and technical jargon. We have also provided plain English summaries of some sections to make the information easier to digest.
We value your privacy and we are committed to meeting the requirements of data protection legislation. We invite you to take the time to read this policy carefully as we want you to be confident that the way Organix handles your data is completely transparent, fair and reasonable.
If you have any questions or concerns do please consumer.care@organix.com
Content
1) Organix – the Data Controller that looks after your data
2) Our legal basis for collecting and processing your data
3) What is ‘personal data’?
4) How Organix gathers personal data
5) Protecting your child’s privacy
6) The data that we seek to collect from you
7) Collection of website data
8) Information that we receive from other sources
9) How we store and protect your personal data
10) How we use your personal data
11) How long we hold your data
12) Who will see your data
13) Your rights and choices
14) Links to other websites
15) Keeping you up to date with changes to our privacy and cookies policy
16) What to do if you have further questions
1) Organix – the Data Controller that looks after your data
Data protection law asks every company to make it clear who is responsible for looking after your personal data, so here are our details:
The Website www.organix.com is owned and operated by Organix Brands Limited ("We", "Organix", "Us"). We are registered in England and Wales under company number 02716145 and have our registered office at The Green House, 120-122 Commercial Road, Bournemouth, Dorset, BH2 5LT. Our VAT number is GB580157934.
Organix Brands Limited is the data controller of the data collected from you.
Who is Organix?
Organix wants a world where healthy, nutritious food is a real choice for everyone. You can find out more about us at Life at Organix | Hero Organix
If you have any questions or concerns about who we are or how we process your personal data then do please consumer.care@organix.com
2) Our legal basis for collecting and processing your data
We at Organix collect and process your data on the basis that we clearly set out how we are going to collect and use your data in this privacy policy, and that you consent to such collection and processing when you register with us.
If at any time you wish to change your preferences or close your account you can do so via our Preference Centre. See section 13) ‘Your Rights and Choices’.
3) What is ‘personal data’?
Personal data is any information which personally identifies you or your child. This might include your name, address or email address. We may also ask for your child’s name, date of birth or your baby’s due date. The information we collect about you and your child will be processed in accordance with this policy.
4) How Organix gathers personal data
The main places that we gather personal data are:
· When you Register for an account on the Organix website: www.organix.com (“the Website”);
· When you subscribe to the Organix email newsletter
Another situation in which we gather personal data, that you may be less aware of, is:
· When you use the Organix website (www.organix.com) and we use tracking devices (known as cookies) to track your web visit
· (For more detail about how and what we do please see the Organix Cookie Policy, which goes into much more detail.)
There are some other, more unusual, situations in which you might give us - or we might ask you for - personal information. These include:
· When you search for a product, participate in discussion boards or other social media functions on the Website;
· When you enter a competition, promotion or survey
· When you report a problem with the Website or contact us regarding a complaint or enquiry.
5) Protecting your child’s privacy
In order to provide you with relevant information about food for your child we need to know:
· Your child’s age or date of birth
· Your child’s name
· Your child’s food preferences
We only collect and process children’s data from parents, and with the consent of the parent.
Providing information about your child is entirely voluntary. You can decide not to give us any information about your child we will send you more generic communications.
6) The data that we seek to collect from you
Data we need to send you relevant, personal emails
At Organix we send emails to you with information about products and food ideas that may be relevant to you and your children. To do this we ask you to tell us your:
· name
· email address
· postal address
· consent to receiving communications from us
· child’s name
· child’s age
· child’s diet preferences
Data that helps us to measure the interest and response to our emails
At Organix we want to understand whether you are opening our emails, and, where relevant, clicking on links within the emails that take them to our website. We do this because we want to learn which emails you find interesting and engaging. We also want to be able to identify people who have stopped opening emails for a period of time, so that we can try to tempt them to start engaging with us again or delete them from our database.
Data we need to retain to answer or resolve an enquiry or complaint
If you contact us with a complaint or enquiry we may keep a record of that correspondence to ensure that we can deal with it effectively.
Data that you share with us in response to a survey
We may also ask you to complete surveys that we use for research purposes, to better understand your opinions, preferences and interests. For example, we might ask you about your interests, and your satisfaction with our products, website, communications or service. Participation in such surveys is always voluntary.
Data that we are provided by third parties
We may also obtain personal information when you have consented to such information being provided to us for example where one of our trusted third party commercial partners host competitions on their website or special offers in conjunction with Organix.[1]
The information provided to us by third parties may include your:
· Name
· Email address
· Postal address
· Consent to receive communications from us
· Child’s name
· Child’s age
· Child’s diet preferences
Any other information which you may provide to us when using the Website.
In future we may host competitions on our website or special offers, either from Organix or in collaboration with trusted third party commercial partners. In such circumstances we will make it clear why we are asking for personal data and refer you to our privacy policy or that of the third party organisation.
[ 1]I understand that the only source that’s may provide personal information is via trusted partners hosting competitions or special offers.
7) Collection of website data
Like many other organisations with a website we use technology to collect and track data on people browsing the website. We do this because we want to know the answers to questions like the following:
• How many people are visiting our website?
• Where have they come from?
• What type of device they use (e.g. desktop computer, tablet or mobile phone) and the internet browser they are using? (This technical information is useful to check that the web pages we have designed appear correctly on their device.)
• Which pages are they visiting and for how long?
• What are they clicking on?
How we collect website data
We use small pieces of data –known as cookies – to track web users behaviour and to recognize that you have visited before. We may also passively collect data through our use of pixels, beacons, log files and other technologies. This data helps us to deliver more helpful information, services, tools and advertisements. For more specific information, please see the Organix Cookie Policy.
Organix uses ‘cookies’ or other similar tracking technologies to do the following:
• To administer the website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• To improve the website to ensure that content is presented in the most effective manner for you and for your computer;
• To allow you to participate in interactive features of our service, when you choose to do so;
• As part of our efforts to keep the website safe and secure;
• To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
• To make suggestions and recommendations to you and other users of the website about goods or services that may interest you or them.
Data that we collect as we track visits to our website
We collect details of visits to the Website including, but not limited to, traffic data, location data, weblogs and other communication data and the resources and links that you access.
Specific information that we collect from people browsing the site
With regard to each of your visits to the website we may automatically collect the following information:
i) technical information, including the Internet protocol ("IP") address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
ii) information about your visit, including information that tells us the site you were previously browsing before coming to the Organix site, the pages you visited on the Organix site, and the page you went to when you left. (Technically this is known as the full Uniform Resource Locator ("URL") clickstream to, through and from the Website, including date and time.) We also track the products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
8) Information that we receive from other sources
The only externally sourced information used is a postcode look up service.
Like many website owners we use a service to that enables us to fill in your complete address based on you supplying your house number and post code. We use this ‘address look up’ service to speed up the registration process for our users.
9) How we store and protect your personal data
We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place 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 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 note: In common with all other website owners we can not guarantee the security of data that you transmit to us over the internet. The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
10) How we use your personal data
When you give us information, such as your name, email address and child’s age, then we use it in the following ways:
• The primary way that we use the personal information that you share with us is to send you relevant emails about our products.
• When you share the age of your child we will use this information to send you email content that is relevant to your child’s age and developmental stage e.g. baby, weaning, young toddler, older toddler.
• A secondary way we may use your data is to provide you with information about goods or services we feel may interest you, if you have consented to this during the subscription or registration process.
• We may also use your information to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you have requested from us.
• We may use your data to notify you about changes to our service or our privacy policy, or to give you notice that we will delete your data, unless you consent to continuing to receive communications.
• We may use your data to ensure that content from the Website is presented in the most effective manner for you and for your computer.
11) How long we will hold your data
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
As a company that provides food for children up to the age of 84 months we will hold your data until your youngest child reaches the age of 84 months. We will then ask you if you wish to continue to receive communications from Organix. If you do not consent to continue we will delete your data.
Organix will delete your data earlier than 84 months if your behaviour indicates that you are no longer interested e.g. if you stop interacting with our emails or website for a period of 24 months. If you stop interacting for 24 months we will treat you as a lapsed customer for a further 6 months. If there is still no interaction we will delete your personal data at that point.
You can, of course, opt-out of receiving marketing from Organix at any time, see section 13) ‘Your Rights and Choices’.
12) Who will see your data
Organix values your privacy and will only share your data with other parties in very specific and limited circumstances. These are explained in this section:
We may share your data within our group of companies or subsidiaries
Organix Brands Limited is part of a larger group of companies called Hero group. You can find out more about them at www.hero-group.ch Hero Group is located outside of the EEA in Switzerland. Switzerland does not have the same data protection laws as the United Kingdom and EEA however the European Commission has given a formal decision that Switzerland provides an adequate level of data protection similar to those which apply in the United Kingdom and EEA so any transfer of your data to the Hero Group will be protected.
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may share your information with selected third parties [ 1]
We will only share your data with third parties for competition purposes. If we are sending out the prize, we will share the information with Royal Mail or FedEx and with a trusted commercial partner if they are sending out a competition prize. We will only share your first name, last name and address.
We will share personal information with law enforcement or other authorities if required by applicable law.
We may disclose your personal information to third parties if some unusual and very specific circumstances apply:
As with any private company, should the company be bought or acquired, or sell off part of its assets, then this could cause your data to be disclosed to the new company owner. Likewise, should the law require us to disclose or share your personal data then we would be obliged to do this. These unusual circumstances are described in more detail below:
i) The Organix customer database is part of the assets of the company. In the event that we sell or buy any business or assets, we may disclose your personal data to the prospective seller or buyer of such business or assets;
ii) If Organix or substantially all of its assets are acquired by a third party, we may disclose personal data held about our customers, as these will be one of the transferred assets;
iii) If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and other agreements; or to protect the rights, property, or safety of Organix, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
[ 1]Organix have confirmed that data is only shared with third parties for the purpose of fulfilment of competitions.
13) Your Rights and Choices
The General Data Protection Regulation (GDPR) is a major piece of data protection law that gives you rights and choices about how your data is used. 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
You can choose whether to receive marketing communications
Organix uses personal data to send subscribers emails with details about Organix products, recipe ideas and other news or offers that we think could be relevant to parents of young children.
If you would like to choose to opt-out of marketing communications you can do this by logging into your account at www.organix.com and unselecting the communications you no longer wish to receive.
You can change your communication preferences at any time
You have a right to restrict the processing of your data. Every email we send to you will include details on how to change your communications preferences or unsubscribe from future communications. If you have an online account with us you may also make changes to your data by logging into your account at www.organix.com or alternatively by contacting us at consumer.care@organix.com
You can choose to correct, update or delete your information
We want to make sure that your information is accurate and up to date. You may update it yourself by logging in to your account at www.organix.com. Alternatively, if you do not have an account, you may contact us using the below details to ask us to correct or remove information you think may be inaccurate.
If you would like us to remove the personal information we hold about you, please contact us at consumer.care@organix.com
If you would like to see what information we hold about you, you can sign into your account at www.organix.com and view the information within your profile. You can also request details we hold about you under the Data Protection Act 1998 and the General Data Protection Regulations – please send a description of the information you would like to see together with proof of your identity to one of the below options. No administration fee will be charged for considering or complying with such a request unless the request is deemed to be excessive.
You have the right to object to your data being used for profiling purposes. All you need to do is contact us at consumer.care@organix.com
You can find out more about your rights under Data Protection
For more information about your rights under the Data Protection Act and the General Data Protection Regulation (GDPR) go to the website of the Information Commissioner’s Office at ico.org.uk.
You can choose to close your account with Organix
You can close your account by sending an email to consumer.care@organix.com or unsubscribe from emails at any time via your account when you are logged in or by clicking unsubscribe in any email from us. You can also contact us by post at The Green House, 120-122 Commercial Road, Bournemouth, Dorset, BH2 5LT.
If you have a complaint about Organix data processing:
We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at www.ico.org.uk/concerns/ or telephone: 0303 123 1113.
14) Links to other websites
The Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
15) Keeping you up to date with changes to our privacy and cookies policy
Any changes we may make to our Privacy & cookies policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes.
16) What to do if you have further questions
If you have any questions or concerns with respect to this policy or the Website you may contact us:
· by email at consumer.care@organix.com
· by post at The Green House, 120-122 Commercial Road, Bournemouth, Dorset, BH2 5LT.