We are Snugs Earphones Limited (referred to hereafter as Snugs), the ‘Controller’ of the personal data you provide to us, as we make decisions on what information we hold and what we do with it. We are committed to managing and protecting the privacy of your personal information in line with all current applicable data privacy laws.
This privacy notice outlines what data we collect, why we collect it and how we manage it while we are holding it. It also highlights your rights with regard to the data. It may change from time to time, so please check it at regular intervals.
Should you have a concern regarding our management of your personal data, or need further information, please do not hesitate to contact us:
- Snugs Earphones Limited, Windwhistle Farm, Treborough, Somerset TA23 0QW, UK
- Email: email@example.com
- Telephone: +44 1984 640582
What personal information do we collect?
We collect basic personal information including your name, email address, phone number, address and ear images in both digital and physical forms to allow us to contact you and provide our product or services. We use a third-party payment system to collect any payment information.
When do we collect it?
We collect personal information from you when you get in touch with us or visit our website, including when purchasing or attempting to purchase our products services or using our portals. We may also acquire your B2B contact information from networking or similar events. If you would like to know more about where we have collected your information from, please contact us using the details above.
Why do we need it?
We require this basic personal information so that we can:
- Enable you to purchase our products or services
- Fulfil and manage your product purchase and your enquiries when using our product
- Improve our websites and applications, including your user experience
- Manage your enquiries
- Send you marketing communications, or invite you to marketing events, in relation to our products and services. You may opt out of marketing at any time
We do not collect any personal information from you that we do not need to facilitate these tasks.
What is our lawful basis for using your information?
We consider we have the following lawful bases to process your data:
- We use the lawful basis of Contract for our existing customers
- Our other business functions, including marketing activities, are in Snugs’ Legitimate Interests to develop the business
- If required to do so, we may need to use your information as part of a legal process
- For cookies, we use the lawful basis of Consent
How do we protect your information?
Snugs is committed to protecting your personal data and has implemented the appropriate systems and procedures to ensure this.
We implement a variety of security measures when a user enters, submits, or accesses their information to maintain the safety of your personal information. All payment transactions are processed through a gateway provider and are not stored or processed on our servers.
All the personal data we collect is managed by our staff in the UK. The information is hosted on servers within the EU, or in the USA under the EU-US Privacy Shield agreement. We use some processors such as CRMs to manage your data and support queries. We may share your data with our business partners when you ask us to book your place with partners to take physical impression of a customer’s ears. We will not share your data with any other third parties, unless the law obliges us to do so.
Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your web browser (if you allow). It enables the site’s systems to recognise your browser and capture and remember certain information.
How long do we keep your personal information?
If you are, or have been, a customer, we will retain your data for up to 15 years after the end of your contract, or the last point of contact (whichever is latest) for marketing as part of our legitimate interest and as part of our statutory obligations.
If you are not a customer and we send you marketing communications, we will keep your information for a maximum of 3 years after the last point of contact.
You can opt out of receiving marketing communications at any time by contacting us using the details above or unsubscribing on the marketing emails we send you.
What are your rights with regard to your personal data?
You have a number of rights regarding the processing of your personal data:
- You have the right to have your personal data corrected if it is not correct or incomplete. Please contact us using the above details, or existing customers may update their details in their portal
- You have the right to have your personal data deleted. Please contact us using the details provided above. Please note that we may not be able to fulfil our contractual obligations without your contact details
- You have the right to have personal data transferred to another party. Please ask us if this is what you would like to do
- You have the right of access to your data. Please contact us and we will let you know what personal data we hold
- You can ask us to restrict the use of your information, by contacting us on the contact details above
- You have the right to register a complaint regarding the use of your personal data to a supervisory authority at any time. The Information Commissioner’s Office is the UK authority, details of which can be found at ico.org.uk
- We do not carry out profiling or automatic decision making
Last Updated: 21/09/2019