1. Introduction
Welcome to Baby Dip LTD trading as Bundle Clubs privacy policy.
BABY DIP LTD trading as Bundle Club respects your privacy and is committed to protecting your personal data. This privacy policy will inform you about what personal data we collect and how we use it. It also tells you about your privacy rights and how the law protects you.
Our services are not intended for children, and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
2. Important information and who we are
About us
We provide family and baby bundle competitions.
Controller
BABY DIP LTD trading as Bundle Club is the controller and responsible for your personal data (collectively referred to as “COMPANY”, “we”, “us” or “our” in this privacy policy).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Contact details
If you have any questions about how we collect and use your information not covered in this privacy notice, or if you wish to speak to someone about our approach to data protection and privacy, please contact our data privacy manager in the following ways:
Full name of legal entity: BABY DIP LTD
Trading as: Bundle Club
Name of data privacy manager: George Oliver
Email address: info@bundleclub.co.uk
Postal address: 12 Old Bexley Lane, Bexley, Kent, DA5 2BN
3. Data we collect and process
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes 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). Nor do we collect any information about criminal convictions and offences.
We will collect the minimum amount of personal data to enable you to enter into any prize draw and competition and allow us to run the promotion. If you are a winner, it may be necessary to collect more detailed information from you in order to award your prize to you. You will be notified of this at the time we notify you that you have won.
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 provide the services you have request (for example, to provide you with goods or services or to enter you into a competition). In this case, we may have to cancel a product or service you have with us or refuse your entry to a competition. We will notify you if this is the case at the time.
4. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing/newsletters to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
- create a member profile on our membership page
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see the section below about our use of cookies for further details.
5. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you (e.g. if you enter into a competition.)
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
- Where we rely on your consent (e.g. before sending third party direct marketing communications). You have the right to withdraw your consent at any time
In this section you will find:
- Details about the personal data we collect and how we use it
- Our lawful basis for processing this data
We will usually process your personal data because you have provided it to us, but in some cases, we may be provided with your personal data by a third-party – if this is the case, we will provide you with information about where we collected your information from, and what we will be doing with it.
| 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 protect ourselves from contract disputes) |
| To respond to emails, questions and other queries | (a) Identity
(b) Contact (c) Content of communication |
(a) Performance of a contract with you (to answer your question) |
| Administer and make payments for invoices, if you’re a supplier | (a) Identity
(b) Contact (c) Financial (d) Transaction |
(a) Performance of a contract with you |
| To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Technical | N/A as not personal data |
| (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) |
| (a) Identity
(b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications |
Consent – when you subscribe to our email list |
If you are a winner of a competition
If you are the winner of the competition, you will be invited to participate in publicity exercises relating to the competition. Your participation is not compulsory but would be greatly appreciated by us. If you do not wish to participate your participation in the competition or chances of winning will not be affected in any way.
However, if you do not wish to participate in any publicity and decline to be named as the winner, we may still have to provide your details to the Advertising Standards Authority (ASA) as proof that the competition has been properly administered and the prize awarded. This is a legal requirement we must comply with. If you require detail of how the ASA will use and process your personal data, please let us know.
Cookies
A cookie is a small piece of data sent from a website and stored on your device by your browser. This Website collects cookies. Please visit our Cookie Policy to learn more about what cookies we collect, why we collect them, and how to change your cookie settings.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
6. Disclosures of your personal data
Third-party processors
We use a number of third-party cloud-based services for the purposes of effectively running our business and providing our services to you. We also use a number of third-party organisations, e.g. accountants, HR support, etc.
In all cases where we are using a third-party service or company, we will only provide the minimal amount of information for the purposes of delivering the service to us and to meet our requirements.
We always carry out due diligence against all our third-party suppliers for the purposes of ensuring their compliance with data protection, maintaining adequate security of your data and ensuring they apply adequate data protection principles to the processing of the data we supply. We also make sure a legally binding contract (sometimes called a Data Processing Agreement or DPA) is also in place to protect your data.
Legal obligations to disclose your personal data
If required by law, we may be required to disclose your personal data to the authorities (e.g. regulators, law enforcement, etc.). We will only do so, if it is lawful for us to do so, and if required we will challenge the need to share your personal data.
Sales or transfer of the business
Should we choose to sell, transfer or merge parts of our business or our assets, we may be required to share your personal data. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy, but you will be contacted about this.
7. International transfers of your personal data
To be able to provide our services, we use a number of service providers (see the disclosures section above), This means when we use these services, we may transfer your data outside of the UK.
If this is the case, we will always ensure an appropriate safeguard is in place. If it’s to a country which the UK government has not identified as having similar and adequate data protection laws, we will ensure appropriate standard contractual terms are in place. These terms are provided by the ICO.
8. 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.
9. 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 (up to 6 years) 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.
In some circumstances you can ask us to delete your data: see “Your legal rights” 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. It would be lawful for us to do so, as it will no longer be classified as personal data and data protection does not apply to non-personal data.
10. Your legal rights
Under current data protection legislation in the UK, you have rights as an individual which you can exercise in relation to the data we store and process about you. You can find more information about your rights on the Information Commissioner’s website: https://ico.org.uk/for-the-public/
If you would like to exercise your rights, or if you have any questions, please use the contact details above.
Right of access (a so-called Subject Access Request)
You have the right to ask us about what data we hold about you, how we process it and to ask us to provide you with a copy of the information, free of charge and within one calendar month of your request.
To make a request for any personal information we hold and process about you, we would prefer it if you could put it in writing or in an email to the addresses above. We will need to verify your identity before providing the information and where necessary may contact you further to ensure we understand what data you are requesting.
Right to rectification (keeping your data up to date)
It is important that any of your data that we process is kept up to date. We may from time to time, if appropriate, ask you to verify your contact details but if you wish to update, change or correct any information we hold about you, please contact us with the details.
Right of erasure (the “right to be forgotten”)
Under some circumstances you may request us to delete your data from our systems. Where this is possible (e.g. we don’t have any legal purpose for continuing to process your data) we will erase it from our systems. If it’s not possible for us to delete your data, we will explain the reasons why.
Right to restrict our processing
In some circumstances you may be able to ask us to limit the processing activity we carry out on your personal data. Those circumstances include: if you contest the accuracy of the personal data; processing is unlawful, but you oppose erasure; you require the retention of the personal data for the establishment, exercise or defence of legal claims; or you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data, but will only process it according to your instructions, unless it is lawful for us to process it otherwise.
Right to portability
Your right to portability allows you to request a machine-readable format of the data you supplied to us and associated service logs (where we store them).
Right to object and to withdraw consent
Where we are processing your data and needed to ask your permission to do so, you are able to withdraw your consent at any time. If you wish to stop receiving our marketing emails you can do so, by clicking on the “unsubscribe” link at the bottom of the email or by contacting us.
You should also contact us, if you wish to raise concerns about the way we are processing your data or would like to raise an objection to the processing, particularly if we are relying on legitimate interest to process your data.
Rights relating to automated decision making or profiling
We do not carry any automated processing which would have a legal impact on yourself and we do not carry out profiling of individuals.
11. Complaints
If you feel this privacy notice does not go far enough in explaining how we have used your personal data, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to info@bundleclub.co.uk
If you want to make a complaint about the way we have processed your personal information, we’d rather you brought it to us in the first instance, but of course you can contact the Information Commissioner’s Office in their capacity as the statutory body that oversees data protection law in the UK – https://ico.org.uk/make-a-complaint/
12. More information
For more information about your data rights and privacy or data protection in general visit the Information Commissioner’s Office website: https://ico.org.uk
13. Changes to our privacy notice
We may change or update elements of this privacy notice from time to time or as required by law. Any substantive changes will be notified to you directly, otherwise the most current version of our privacy notice is available on our website at www.bundleclub.co.uk