HollyBloom Privacy Notice

This Privacy Notice was last reviewed in September 2024

INTRODUCTION

For the purpose of this Privacy Notice, “you” or “your” means (as applicable): (i) the individual representatives or end users of any of our customers or vendors; and (ii) other individual users of our Services or the visitors to https://hollybloom.co.uk/ (our “Website”). “HollyBloom”, “we”, “us”, or “our” means HollyBloom UK operating as a sole trader in England and Wales.

This Privacy Notice sets out the basis on which any Personal Data we collect from you, that you provide to us, or that we collect from third parties will be processed by us as a controller. This Privacy Notice also sets out how you can instruct us if you prefer to limit the use of that Personal Data, and the procedures that we have in place to safeguard your Personal Data. Please read the following carefully to understand our processes and practices regarding your personal data and how we will treat it.

Our Website is not intended for children and we do not knowingly collect data relating to children.

HollyBloom has developed the Website for users to upload and/or discover wellness events. We offer other related services to customers such as social media and other event promotion (the “Services”).

1.          IMPORTANT INFORMATION AND WHO WE ARE

This Privacy Notice applies to all Personal Data we process as a controller, as defined and in accordance with “Applicable Data Protection Legislation”, which means: (i) in the EU, all applicable data protection and privacy legislation in force from time to time, including the General Data Protection Regulation ((EU) 2016/679) (“GDPR”); and (ii) in the UK, the GDPR until such time it is repealed or ceases to apply in the UK and all applicable data protection and privacy legislation in force from time to time including the Data Protection Act 2018 (as applicable).

If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact us using the details set out below:

Full name of legal entity:          HollyBloom UK

Email address:                         Info@hollybloom.co.uk

You have the right to make a complaint at any time to the supervisory authority for data protection issues, the Information Commissioner’s Office of the United Kingdom (the “ICO”). Please see their website for further details on how to make a complaint (https://ico.org.uk/). We would, however, appreciate the chance to address your concerns before you approach the ICO, so please contact us in the first instance.

2.          CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFOROM US OF CHANGES

We review this Privacy Notice regularly. Please check back frequently to see any updates or changes to the Privacy Notice.

It is important that any Personal Data we hold about you is accurate and up to date. Please keep us informed if your Personal Data changes during your relationship with us.

3.          THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified and that we control (this excludes any personal data we process on behalf of our customers as a processor such as our customers bank accounts data). 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 individuals, as applicable such as:

• Identity Data includes surname and first name, mailing address, email address, phone number, and login details. 

• Professional Data includes in relation to an individual, company name, company number, company address, job title, post, position, and business sector (and “know your customer” data – e.g. ID or passport copies – when we are onboard new customers). 

• Technical Data includes the internet protocol (“IP”) address(es) used to connect your computer(s) to the internet, 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 our Website. 

• Customer Profile Data includes: (i) as regards to our customers: details and records of any Services commissioned, or supplied, and any queries, comments or complaints sent to us by their personnel in relation to our business relationship with them. 

• Usage Data includes information about how visitors use our Website, or our Services to keep records of the services provided, but always excluding any customers’ bank account data (e.g. account balances or transactions). 

• Marketing and Communications Data includes your preferences regarding your receipt of newsletters or other marketing from us, and your communication preferences. 

• Vendors’ Financial Data: in connection with vendors that provide services to us, their contact details and financial details (when such details include Personal Data) to allow us to pay their fees.

Unless we obtain your informed consent, or it is otherwise required by law in connection with a contract we have with you, 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) or any information about criminal convictions and offences.

Where we are required by law, or under the terms of a contract we have with you, to collect Personal Data, and you fail to provide that data when requested, we may not be able to perform any contract with you. If this happens, we will notify you.

4.          HOW WE COLLECT YOUR PERSONAL DATA

We collect your Personal Data through a number of methods, including:

• Direct Interactions

You may give us your Identity, Contact, and Marketing Data, by filling in forms on our Website, or by corresponding with us by post, phone, email or otherwise.

• Automated Technologies or Interactions

As you interact with our Website, we will automatically collect Technical and Usage Data from your equipment, browsing actions, and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy 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 the company you represent or work for;

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.

Generally, we do not rely on consent as a legal basis for processing your personal data, although we will get your consent (or rely on soft opt-in) before sending third party direct marketing communications to you via email or text message (see Section 7 below). You have the right to withdraw consent to marketing at any time by contacting us.

We have set out below, in table format, a description of how we plan to use your Personal Data, and on which legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Please note that we may process your Personal Data for more than one lawful ground depending on the specific purpose.

MARKETING AND PROMOTIONAL OFFERS

We may use your Identity, Professional, Technical, Usage, and Customer Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased our services and you have not opted out of receiving that marketing. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

OPTING OUT

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of a product or service purchase, product/service experience, or other transactions.

Cookies

For more information about the cookies we use and how to change your cookie preferences, please see our cookie policy.

CHANGE OF PURPOSE

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

6.          DISCLOSURE OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below, for the purposes set out in Section 6 above:

• Business partners where doing so is necessary for the performance of our contractual relationship with them (always in accordance with Data Protection Legislation);
• Professional advisers including lawyers, bankers, auditors and insurers;
• HM Revenue & Customs (United Kingdom), regulators, and other authorities; and
• any third parties to whom we may choose to sell, transfer or merge parts of the HollyBloom business or assets.

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes, and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

7.          INTERNATIONAL TRANSFERS

HollyBloom does not transfer Personal Data outside the EU, the European Economic Area (“EEA”) or the United Kingdom. The Personal Data that we collect from you will be transferred to, and stored at, a destination inside the EU, the EEA or the United Kingdom. It will also be processed by staff operating inside the EU, the EEA or the United Kingdom who work for us or for one of our third-party service providers. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice.

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 if we are required to do so.

9.          HOW LONG WE WILL USE YOUR 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 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.

Please contact us using the contact details set out in this Privacy Notice if you have any questions about data retention.

10.       YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. If you wish to exercise any of your legal rights, please contact us using the contact details set out in this Privacy Notice. 

You have the right to:

• Request access to your Personal Data

This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction of the Personal Data that we hold about you.

This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your Personal Data.

This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing of your Personal Data.

Where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Request restriction of processing of your Personal Data.

This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) If you want us to establish the data’s accuracy; (b) Where our use of the data is unlawful but you do not want us to erase it; (c) Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; and  (d) You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your Personal Data to you or to a third party.

We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw consent.

You can withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances. We will notify you if this is the case at the time.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month to respond if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

EXCEPTIONS

It may not be possible for us to delete your Personal Data if we are required to keep it by law, or if we hold it in connection with a contract with you or your employer. Similarly, access to your Personal Data may be refused if making the information available would reveal Personal Data about another person or if we are legally prevented from such disclosure.

ACCESSIBILITY OF PRIVACY NOTICE

We are committed to provide a Website and Privacy Notice that is accessible to the widest possible audience regardless of technology or ability. If you experience difficulty in accessing any part of the Website or the Privacy Notice, please email us at Info@hollybloom.co.uk and we will work with you to provide the information or item you seek through an alternate communication method or that is accessible for you consistent with Applicable Data Protection Legislation. 

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.